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510(k) Data Aggregation

    K Number
    K190427
    Device Name
    Immucise
    Manufacturer
    Date Cleared
    2019-07-18

    (146 days)

    Product Code
    Regulation Number
    880.5860
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Immucise

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

    The Immucise Intradermal Injection System is indicated for intradermal injections of FDA approved drugs. The system is to be used in the deltoid region for infants aged two months (excluding low birth weight and/or preterm birth) to adults.

    Device Description

    The Immucise Intradermal Injection System is a single use, electron beam radiation sterilized device that is designed to be used for intradermal injections of FDA approved drugs. This system consists of an Intradermal Injection Needle and an Immucise Syringe. The system is made of common materials used in needles and syringes. The Immucise Intradermal Injection Needle is comprised of a needle base. The Immucise Syringe is comprised of a barrel, a gasket and a plunger. The sterile Immucise Intradermal Injection Needle and Immucise Syringe are packed separately and assembled prior to use. The Immucise Intradermal Injection System is operated by a manual process.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and study information for the Immucise Intradermal Injection System, based on the provided FDA 510(k) summary:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document primarily focuses on demonstrating substantial equivalence to a predicate device (K181369) for an expanded indication (including infants). Therefore, the "acceptance criteria" are largely implied by meeting the same performance standards as the predicate, or by achieving successful outcomes in functionality tests.

    Acceptance Criteria CategoryAcceptance CriteriaReported Device Performance
    Bench Test PerformanceDevice meets predetermined acceptance criteria for non-aged and aged samples as established for the primary predicate (K181369). (Specific criteria not detailed in this document but implied as met by K181369).Bench testing for Immucise Intradermal Injection System was performed in K181369 using non-aged and aged samples and met the predetermined acceptance criteria. No additional bench tests were deemed necessary for the expanded indication as the subject device is identical to K181369.
    Animal Study (Functionality)Successful wheal formation post-injection for the Immucise Intradermal Injection System, comparable to the reference device (West Intradermal Adapter), for the expanded patient population (infants to adults). (Specific success rate not quantified but implied as met).The study "evaluated the efficacy of Immucise Intradermal Injection System for the indication for use. The test compared the post-injection wheal formation success rate between the Immucise Intradermal Injection System and the reference device of West Intradermal Adapter." The conclusion states, "Terumo concludes that the Immucise Intradermal Injection System has been found to be substantially equivalent for the intended use and for the target patient population without raising different questions of safety and effectiveness." This implies successful wheal formation in the target population.
    Animal Study (Histopathological)Validation of the required injection depth for intradermal injections in the expanded patient population (infants to adults). (Specific depth criteria not detailed but implied as met).The study was "conducted to validate the injection depth required for the indications for use." The conclusion states, "Terumo concludes that the Immucise Intradermal Injection System has been found to be substantially equivalent for the intended use and for the target patient population without raising different questions of safety and effectiveness." This implies successful validation of injection depth for the target population.
    Material BiocompatibilityPatient contacting parts assessed in accordance with ISO-10993-1.The finished device's patient contacting parts were assessed in accordance with tests recommended in the FDA Guidance - Use of International Standard ISO-10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process." It is stated as "Biocompatible."
    Sterilization Method (Electron Beam)Device able to be sterilized effectively by Electron Beam radiation.Electron Beam radiation.
    Shelf LifeNeedle: 36 months, Syringe: 12 months.Needle: 36 months, Syringe: 12 months.

    2. Sample Size and Data Provenance for Test Set:

    • Bench Test: No specific sample sizes for "non-aged and aged samples" are provided in this document, but it refers to the prior submission K181369. Data provenance is not explicitly stated beyond "performed in K181369."
    • Animal Test: No specific sample sizes for the animal study are provided in this document. The data provenance is Terumo (Japan). The study was conducted specifically to support the expanded indication, suggesting it was prospective for this submission, though the methodology was based on a previous study.

    3. Number of Experts and Qualifications for Ground Truth (Test Set):

    • Neither the bench tests nor the animal studies described in this document involved human experts establishing ground truth in the way a clinical study with image interpretation might.
    • For the animal study, the "ground truth" (e.g., successful wheal formation, validated injection depth) would have been assessed by trained personnel through observation and potentially histological analysis. No specific number or qualifications of experts are mentioned.

    4. Adjudication Method for Test Set:

    • This type of information (e.g., 2+1, 3+1) is typically relevant for studies involving subjective human interpretation, such as radiology reads.
    • For bench and animal studies (focused on objective measurements and physiological responses), such adjudication methods are not applicable. The assessment would be based on predefined protocols and measurements.

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

    • No, a multi-reader multi-case (MRMC) comparative effectiveness study was not done.
    • This device is a physical medical device (intradermal injection system), not an AI-powered diagnostic tool that human readers would use in conjunction with. The comparative effectiveness focused on technical performance against a reference device, not human reader improvement with AI.

    6. Standalone (Algorithm Only) Performance:

    • No, standalone performance was not done.
    • Again, this is a physical medical device. The concept of "algorithm only" performance is not applicable here as there is no AI algorithm involved in its direct function. The device's performance is its physical function.

    7. Type of Ground Truth Used:

    • Bench Test: Physical and functional measurements against predefined specifications (e.g., durability, material properties, dimensional accuracy).
    • Animal Test: Direct physiological observations (wheal formation) and histological evaluation for injection depth, based on in-house standards designed to confirm intended physiological effects of intradermal injection.

    8. Sample Size for Training Set:

    • This concept is not applicable for this device. This is a physical medical device, not a machine learning model that requires a training set. The "training" in the context of device development would refer to design iterations and engineering testing, not data used to train an algorithm.

    9. How Ground Truth for Training Set Was Established:

    • Not applicable, as there is no training set in the context of machine learning. The "ground truth" for the device's design and engineering would be established through established engineering principles, material science, and regulatory standards.
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    K Number
    K181369
    Manufacturer
    Date Cleared
    2018-11-13

    (174 days)

    Product Code
    Regulation Number
    880.5570
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Immucise Intradermal Injection System

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

    The Immucise Intradermal Injection System is indicated for intradermal injections of FDA approved drugs. The system is to be used in the deltoid region for adults.

    Device Description

    The Immucise Intradermal Injection System is a single use, electron beam radiation sterilized device that is designed to be used for intradermal injections of FDA approved drugs. The system consists of a needle and syringe that are packed separately and assembled prior to use. The Immucise Intradermal Injection Needle consists of a needle tube and needle base, and the Immucise Syringe consists of a barrel, gasket and plunger.

    AI/ML Overview

    The Immucise Intradermal Injection System, intended for intradermal injections of FDA approved drugs in the deltoid region for adults, did not undergo a comparative effectiveness study with human readers assisted by AI, nor a standalone AI algorithm performance study, as it is a medical device (needle and syringe system) rather than an AI-powered diagnostic or therapeutic tool. Therefore, sections pertaining to MRMC effect size, standalone AI performance, sample sizes for test/training sets, data provenance, number and qualifications of experts, and adjudication methods for AI performance are not applicable.

    The device's performance was evaluated through a series of non-clinical tests (bench, animal, human factors, biocompatibility, sterilization, and packaging) to demonstrate substantial equivalence to predicate devices and ensure it met predetermined acceptance criteria.

    1. Table of Acceptance Criteria and Reported Device Performance:

    Test CategoryTest NameStandard / Acceptance CriteriaReported Device Performance
    Bench TestingCleanlinessISO 7864:2016 Section 4.3Met predetermined acceptance criteria.
    Limits for acidity or alkalinityISO 7864:2016 Section 4.4Met predetermined acceptance criteria.
    Limits for extractable metalsISO 7864:2016 Section 4.5Met predetermined acceptance criteria.
    Positive pressure liquid leakageISO 7864:2016 Section 4.8.1; ISO 80369-7:2016 Section 6.1Met predetermined acceptance criteria.
    Sub-atmospheric pressure air leakageISO 7864:2016 Section 4.8.1; ISO 80369-7:2016 Section 6.2Met predetermined acceptance criteria.
    Stress crackingISO 7864:2016 Section 4.8.1; ISO 80369-7:2016 Section 6.3Met predetermined acceptance criteria.
    Resistance to separation from axial loadISO 7864:2016 Section 4.8.1; ISO 80369-7:2016 Section 6.4Met predetermined acceptance criteria.
    Resistance to separation from unscrewingISO 7864:2016 Section 4.8.1; ISO 80369-7:2016 Section 6.5Met predetermined acceptance criteria.
    Resistance to overridingISO 7864:2016 Section 4.8.1; ISO 80369-7:2016 Section 6.6Met predetermined acceptance criteria.
    Surface finish and visual appearance (Needle tube)ISO 7864:2016 Section 4.10.1; ISO 9626:2016 Section 5.2Met predetermined acceptance criteria.
    Cleanliness (Needle tube)ISO 7864:2016 Section 4.10.1; ISO 9626:2016 Section 5.3Met predetermined acceptance criteria.
    Limits for acidity and alkalinity (Needle tube)ISO 7864:2016 Section 4.10.1; ISO 9626:2016 Section 5.4Met predetermined acceptance criteria.
    Dimensions (Needle tube)ISO 7864:2016 Section 4.10.1; ISO 9626:2016 Section 5.6Met predetermined acceptance criteria.
    Stiffness (Needle tube)ISO 7864:2016 Section 4.10.1; ISO 9626:2016 Section 5.8Met predetermined acceptance criteria.
    Resistance to breakage (Needle tube)ISO 7864:2016 Section 4.10.1; ISO 9626:2016 Section 5.9Met predetermined acceptance criteria.
    Resistance to corrosion (Needle tube)ISO 7864:2016 Section 4.10.1; ISO 9626:2016 Section 5.10Met predetermined acceptance criteria.
    Freedom from defectsISO 7864:2016 Section 4.10.3Met predetermined acceptance criteria.
    LubricantISO 7864:2016 Section 4.10.4Met predetermined acceptance criteria.
    Needle pointISO 7864:2016 Section 4.11Met predetermined acceptance criteria.
    Bond between hub and needle tubeISO 7864:2016 Section 4.12Met predetermined acceptance criteria.
    Patency of lumenISO 7864:2016 Section 4.13Met predetermined acceptance criteria.
    Needle lengthIn-house StandardMet predetermined acceptance criteria.
    Bevel lengthIn-house StandardMet predetermined acceptance criteria.
    Needle hub strengthIn-house StandardMet predetermined acceptance criteria.
    Dead volumeIn-house StandardMet predetermined acceptance criteria.
    General (Syringe)ISO 7886-1:2017 Section 6.1Met predetermined acceptance criteria.
    Limits for acidity or alkalinity (Syringe)ISO 7886-1:2017 Section 6.2Met predetermined acceptance criteria.
    Limits for extractable metals (Syringe)ISO 7886-1:2017 Section 6.3Met predetermined acceptance criteria.
    Lubricant (visual inspection - Syringe)ISO 7886-1:2017 Section 7Met predetermined acceptance criteria.
    Lubricant (quantity - Syringe)ISO 7886-1:2017 Section 7Met predetermined acceptance criteria.
    Tolerance on graduated capacityISO 7886-1:2017 Section 8Met predetermined acceptance criteria.
    Barrel (rotation of flange)ISO 7886-1:2017 Section 10Met predetermined acceptance criteria.
    Barrel (visual inspection of flange)ISO 7886-1:2017 Section 10Met predetermined acceptance criteria.
    Plunger stopper /plunger assembly (Detachment of plunger stopper from plunger)ISO 7886-1:2017 Section 11Met predetermined acceptance criteria.
    Piston /plunger assembly (Distance between plunger and flange)ISO 7886-1:2017 Section 11Met predetermined acceptance criteria.
    NozzleISO 7886-1:2017 Section 12.1; ISO 80369-7:2016 Section 5Met predetermined acceptance criteria.
    Positive pressure liquid leakage (Syringe)ISO 7886-1:2017 Section 12.1; ISO 80369-7:2016 Section 6.1Met predetermined acceptance criteria.
    Sub-atmospheric pressure air leakage (Syringe)ISO 7886-1:2017 Section 12.1; ISO 80369-7:2016 Section 6.2Met predetermined acceptance criteria.
    Stress cracking (Syringe)ISO 7886-1:2017 Section 12.1; ISO 80369-7:2016 Section 6.3Met predetermined acceptance criteria.
    Resistance to separation from axial load (Syringe)ISO 7886-1:2017 Section 12.1; ISO 80369-7:2016 Section 6.4Met predetermined acceptance criteria.
    Resistance to separation from unscrewing (Syringe)ISO 7886-1:2017 Section 12.1; ISO 80369-7:2016 Section 6.5Met predetermined acceptance criteria.
    Resistance to overriding (Syringe)ISO 7886-1:2017 Section 12.1; ISO 80369-7:2016 Section 6.6Met predetermined acceptance criteria.
    Dead SpaceISO 7886-1:2017 Section 13.1Met predetermined acceptance criteria.
    Freedom from air leakage past pistonISO 7886-1:2017 Section 13.2Met predetermined acceptance criteria.
    Freedom from liquid leakage past pistonISO 7886-1:2017 Section 13.2Met predetermined acceptance criteria.
    Force to operate the pistonISO 7886-1:2017 Section 13.3Met predetermined acceptance criteria.
    Fit of plunger stopper/plunger in barrelISO 7886-1:2017 Section 13.4Met predetermined acceptance criteria.
    Sliding resistanceIn-house Standard (verified requirements of ISO 7886-1:2017 Section 11)Met predetermined acceptance criteria.
    Stopper forceIn-house Standard (verified requirements of ISO 7886-1:2017 Section 11)Met predetermined acceptance criteria.
    Drug flowabilityIn-house StandardMet predetermined acceptance criteria.
    Pressure resistanceIn-house StandardMet predetermined acceptance criteria.
    Particulate matterUSP 788Met USP acceptance criteria.
    Animal StudyIntradermal injection functionalitySuccessful wheal formation and histopathological evaluation validating injection depth for intended use, showing substantial equivalency to predicate device.Met predetermined acceptance criteria; demonstrated substantial equivalency and validated injection depth.
    Human Factors and Usability Engineering StudyUser interface evaluationNo use-errors determined to cause serious harm, in accordance with FDA guidance "Applying Human Factors and Usability Engineering to Medical Devices," issued on February 3, 2016.No use errors causing serious harm were found.
    BiocompatibilityCytotoxicity, Sensitization, Intracutaneous Reactivity, Acute Systemic Toxicity, Pyrogenicity, Hemolysis (Indirect Contact), Physicochemical Profile (Non-aged, Sterile, Finished Device)ISO 10993-1 and FDA Guidance for Industry and Food and Drug Administration Staff - Use of International Standard ISO-10993-1Demonstrated an acceptable biocompatibility profile.
    Cytotoxicity, Hemolysis (Indirect Contact), Physicochemical Profile (Accelerated Aged, Sterile, Finished Device)ISO 10993-1 and FDA Guidance for Industry and Food and Drug Administration Staff - Use of International Standard ISO-10993-1Demonstrated an acceptable biocompatibility profile throughout shelf life.
    SterilizationSterility Assurance Level (SAL)ISO 11137-1/ISO 11137-2 to provide SAL of 10-6Achieved SAL of 10-6.
    PackagingPackage integrityISTA 3A (after environmental conditioning and simulated transportation)All packaging was deemed acceptable for product protection and sterility maintenance.

    2. Sample size used for the test set and the data provenance: Not applicable. The "test set" in this context refers to the samples of the device used for the various non-clinical performance evaluations. The provenance of these samples would be the manufacturer's production line in Japan (Kofu Factory of Terumo Corporation). All testing was conducted prospectively as part of the 510(k) submission.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. This refers to the evaluation of the medical device's physical and functional properties against established engineering and biological standards, not diagnostic or interpretive tasks requiring expert ground truth in the context of AI studies.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable. This refers to consensus methods for establishing ground truth, typically in image interpretation or diagnostic performance studies. The performance of this device was assessed against objective, measurable criteria defined by international standards (ISO, USP) and in-house 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. The Immucise Intradermal Injection System is a medical device (needle and syringe system), not an AI-powered diagnostic or therapeutic tool for which such studies would be relevant.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable. The Immucise Intradermal Injection System is a medical device, not an AI algorithm. Its performance is inherent to its physical design and manufacturing.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc): The "ground truth" for the device's performance was established by:
    * Bench Testing: Adherence to international standards (ISO, USP) and in-house established specifications.
    * Animal Study: Direct observation of wheal formation and histopathological evaluation of injection depth.
    * Human Factors and Usability Engineering Study: Observation of user interaction to identify potential use-errors that could cause serious harm, as per FDA guidance.
    * Biocompatibility: Results of standardized biological tests (e.g., cytotoxicity, sensitization) evaluated against ISO 10993-1 criteria.
    * Sterilization: Demonstrated Sterility Assurance Level (SAL) of 10-6 per ISO 11137 standards.
    * Packaging: Verification of package integrity against ISTA 3A standards.

    8. The sample size for the training set: Not applicable. This device is not an AI algorithm requiring a training set.

    9. How the ground truth for the training set was established: Not applicable. As the device is not an AI algorithm, there is no training set or associated ground truth.

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