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510(k) Data Aggregation

    K Number
    K182216
    Device Name
    Merit Syringe
    Date Cleared
    2018-11-06

    (83 days)

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

    Merit Syringe

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

    The Merit Syringe is used to inject fluids into, or withdraw fluids from, the body.

    Device Description

    The Merit Syringe contains a calibrated hollow barrel into which is inserted a closely fitted movable plunger and tip. The barrel contains a fixed male luer connector, which is compatible with female luer hubs.

    AI/ML Overview

    Here's an analysis of the provided text regarding acceptance criteria and supporting studies for the Merit Syringe, based on the given requirements:

    The document does not contain information about a device that uses AI, or a device that specifically needs human readers to interpret its output. Thus, questions 2, 3, 4, 5, 6, 7, 8, and 9 from your prompt are not applicable to the provided text. The device described, the "Merit Syringe," is a mechanical medical device (a piston syringe) and its evaluation focuses on physical performance, material compatibility, and sterilization.

    1. A table of acceptance criteria and the reported device performance

    Acceptance Criteria CategorySpecific Standard/RequirementReported Device Performance
    Material & DesignSame materials as predicate device (K152783): barrel (clear cyclo-olefin polymer), plunger (polycarbonate or ABS), seal (silicone), lubricant (silicone)Met: Materials of the subject device are identical to the predicate device.
    BiocompatibilityEndpoints previously evaluated under K152783: Cytotoxicity, Sensitization, Irritation, Acute Systemic Toxicity, Pyrogenicity, Hemocompatibility. (FDA Guidance, ISO 10993-1)Met: Biocompatibility testing provided in K081361 demonstrated the biocompatibility of the subject device for the intended use, as materials are identical to the predicate (K152783). The specified biocompatibility endpoints were previously evaluated.
    SterilizationSterility process cleared under K152783 (ISO 11135:2014, ISO 11607-1:2006, AAMI TIR 28:2009)Met: The subject device was adopted into existing validated sterility processes (EO sterilization with a 3-year shelf life) per AAMI TIR 2009, with the process validated under K152783 using ISO 11135 and ISO 11607-1.
    Performance Bench TestingISO 7886-1:2017 (Sterile hypodermic syringes for single use - Part 1: Syringes for manual use)Met: Testing demonstrated that the subject device met the predetermined acceptance criteria and supports the 3-year shelf life. (For both general performance and dimensional accuracy of graduation lines).
    Performance Bench TestingISO 594-2:1998 (Conical fittings with 6% (Luer) taper for syringes, needles and certain other medical equipment – Part 2: Lock fittings)Met: Testing demonstrated that the subject device met the predetermined acceptance criteria and supports the 3-year shelf life. (Specific to luer lock connector performance).
    Risk ManagementISO 14971:2007 (Medical devices – Application of risk management to medical devices)Met: A risk analysis was conducted in accordance with ISO 14971:2007, and in all non-clinical testing, the predetermined acceptance criteria were met, leading to a conclusion of substantial equivalence.
    Graduation AccuracyCompliant with ISO 7886-1Met: Printed with accurate graduation lines that are compliant with ISO 7886-1. (This is a specific performance aspect within the broader ISO 7886-1 compliance).
    Shelf Life3-year shelf lifeMet: Results of performance testing demonstrate support for the 3-year shelf life.

    2. Sample size used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective)

    Not applicable. This is a medical device (syringe) clearance based on bench testing to established standards and comparison to a predicate device, not on clinical study data involving patients or AI performance on a test set.

    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. Ground truth for a diagnostic device/AI is not relevant for a mechanical syringe. Performance is measured against engineering standards.

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

    Not applicable. No expert adjudication is described for a syringe's performance against engineering 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 device is not an AI-assisted diagnostic tool.

    6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done

    Not applicable. There is no algorithm for a mechanical syringe.

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

    Not applicable. The "ground truth" for this device's performance is compliance with recognized international and FDA standards for syringes (e.g., ISO 7886-1, ISO 594-2) and biocompatibility standards (ISO 10993-1).

    8. The sample size for the training set

    Not applicable. This device does not involve a "training set" as it is not an AI/machine learning device.

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

    Not applicable. As above, no training set or ground truth in the context of AI/ML is relevant for this device.

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    K Number
    K182279
    Device Name
    Merit Syringe
    Date Cleared
    2018-11-06

    (76 days)

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

    Merit Syringe

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

    The Merit Syringe is used to inject fluids into, or withdraw fluids from, the body.

    Device Description

    The Merit Syringe contains a calibrated hollow barrel into which is inserted a closely fitted, plunger, and O-ring seal. The barrel contains an ISO 594-2 compliant fixed male luer connector, which is compatible with ISO 594-2 compliant female luer hubs. The syringe uses a fluorocarbon based non-silicone lubricant.

    AI/ML Overview

    This document describes the premarket notification (510(k)) for the Merit Syringe, which is a piston syringe used to inject or withdraw fluids from the body. Given the nature of this submission (a 510(k) for a Class II medical device like a syringe), the "acceptance criteria" and "study that proves the device meets the acceptance criteria" refer to performance bench testing against recognized consensus standards and biocompatibility testing, rather than studies involving human readers or AI algorithms.

    Here's a breakdown based on the provided text:

    1. A table of acceptance criteria and the reported device performance

    The document doesn't provide a direct table format for each acceptance criterion with a pass/fail. Instead, it states that the device "complies with the FDA recognized consensus standards ISO 7886-1 and ISO 594-2" and that "Results of the testing demonstrate that the subject device met the acceptance criteria sufficient for its intended use."

    The general categories of acceptance criteria and the overall reported performance are:

    Acceptance Criteria CategoryReported Device Performance
    Performance TestingComplies with ISO 7886-1:2017 (Sterile hypodermic syringes for single use – Part 1: Syringes for manual use) and ISO 594-2:1998 (Conical fittings with 6% (Luer) taper for syringes, needles and certain other medical equipment - Part 2: Lock fittings).
    Biocompatibility TestingEvaluation conducted in accordance with FDA Guidance Document “Use of International Standard ISO-10993” and ISO 10993-1.
    SterilizationComplies with ISO 11135:2014 (Ethylene oxide sterilization), ISO 10993-7:2008 (Ethylene oxide sterilization residuals), and AAMI TIR 28:2009 (Product adoption and process equivalency for ethylene oxide sterilization).
    PackagingComplies with ISO 11607-1:2006 (Packaging for Terminally Sterilized Medical Devices), ASTM D4169-16:2016 (Performance Testing of Shipping Containers and Systems), ASTM F1980-16 (Accelerated Aging of Sterile Barrier Systems for Medical Devices), and ISO 2233:2000 (Conditioning for testing).

    Specific Biocompatibility Tests Performed:

    • Cytotoxicity
    • Sensitization
    • Irritation
    • Acute Systemic Toxicity
    • Pyrogenicity
    • Hemolysis
    • Bacterial Endotoxins (AAMI/ANSI ST72:2011/(R) 2016)
    • Pyrogen Test (United States Pharmacopeia 40, National Formulary 35, )

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

    The document does not specify the exact sample sizes used for each test (e.g., number of syringes tested for flow rate, number of samples for biocompatibility). The testing is described generally as "a battery of tests" and "Performance testing... was completed against FDA recognized consensus standards." For device performance (like the Merit Syringe), the "test set" would typically refer to the samples of the manufactured device subjected to the physical and chemical tests, not a dataset of patient images or clinical data.

    Data provenance: Not explicitly stated, as this refers to a medical device's physical/chemical performance, not clinical data collection. It's implied the testing was performed by "Merit Medical Systems, Inc." directly or by a contracted lab.

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

    This question is not applicable to a 510(k) submission for a piston syringe or the type of performance testing described. "Ground truth" and "experts" in this context typically refer to clinical validation studies, particularly for AI/imaging devices, where expert radiologists/clinicians establish diagnostic labels. For a syringe, the "ground truth" is established by the specifications of the recognized consensus standards (e.g., ISO 7886-1 defines specific dimensions, pressures, and flow rates that the device must meet).

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

    Not applicable. Adjudication methods are used in clinical studies, particularly for interpreting medical images or patient outcomes, not for bench testing of a physical device. The "adjudication" in this context would be the pass/fail criteria defined by the consensus standards themselves, and the testing results are objectively measured.

    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. MRMC studies are specific to evaluating the diagnostic performance of medical imaging devices or AI algorithms used in conjunction with human interpretation. This submission is for a physical medical device (syringe) and does not involve imaging or AI.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    Not applicable. This device is not an algorithm. "Standalone performance" would refer to the bench testing of the syringe against the specified standards, as described in section 1.

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

    For this type of device, the "ground truth" is defined by the technical specifications and performance requirements outlined in the referenced international consensus standards (e.g., ISO 7886-1, ISO 594-2). These standards stipulate acceptable ranges for attributes like dimensional accuracy, fluid leakage, plunger force, and luer connection integrity. Biocompatibility testing refers to established chemical and biological test methods detailed in standards like ISO 10993.

    8. The sample size for the training set

    Not applicable. This device does not involve a "training set" in the context of machine learning or AI.

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

    Not applicable, for the same reasons as #8.

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    K Number
    K173601
    Device Name
    Merit Syringe
    Date Cleared
    2018-01-31

    (71 days)

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

    Merit Syringe

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

    The Merit Syringe is used to inject fluids into, and withdraw fluids from, the body.

    Device Description

    The Merit Syringe contains a calibrated hollow barrel into which is inserted a closely fitted movable plunger and tip or O-Ring. The barrel contains an ISO 594-2 compliant fixed male luer connector, which is compatible with ISO 594-2 compliant female luer hubs.

    AI/ML Overview

    The provided document describes the acceptance criteria and the study conducted for the Merit Syringe, which is a medical device used to inject and withdraw fluids from the body.

    Here's the information extracted from the document:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document states that the Merit Syringe complies with the FDA recognized consensus standards ISO 7886-1 and ISO 594-2. The performance data for biocompatibility is also mentioned.

    Acceptance Criteria (from ISO 7886-1 and ISO 594-2)Reported Device Performance
    ISO 7886-1:Met acceptance criteria sufficient for its intended use.
    CleanlinessMet (implied by compliance with standard)
    Graduated ScaleMet (implied by compliance with standard)
    Limits for acidity or alkalinityMet (implied by compliance with standard)
    BarrelMet (implied by compliance with standard)
    Limits for extractable metalsMet (implied by compliance with standard)
    Piston/Plunger AssemblyMet (implied by compliance with standard)
    LubricantMet (implied by compliance with standard)
    NozzleMet (implied by compliance with standard)
    Tolerance on Graduated CapacityMet (implied by compliance with standard)
    Performance - Freedom from air and liquid leakage past pistonMet (implied by compliance with standard)
    ISO 594-2:Met acceptance criteria sufficient for its intended use.
    GaugingMet (implied by compliance with standard)
    Unscrewing torqueMet (implied by compliance with standard)
    Liquid leakageMet (implied by compliance with standard)
    Ease of assemblyMet (implied by compliance with standard)
    Air leakageMet (implied by compliance with standard)
    Resistance to overridingMet (implied by compliance with standard)
    Separation forceMet (implied by compliance with standard)
    Stress crackingMet (implied by compliance with standard)
    Biocompatibility (based on ISO 10993-1, 4, 5, 7, 10, 11; AAMI/ANSI ST72; ASTM F756-08; USP 37 NF 32 ):Met acceptance criteria.
    CytotoxicityPerformed and compliant
    SensitizationPerformed and compliant
    IrritationPerformed and compliant
    Acute Systemic ToxicityPerformed and compliant
    PyrogenicityPerformed and compliant
    HemolysisPerformed and compliant
    Ethylene oxide sterilization residualsPerformed and compliant (ISO 10993-7)
    Sterilization dose (Radiation)Performed and compliant (ISO 11137-2)
    Packaging integrity (for sterile devices)Performed and compliant (ISO 11607-1, ASTM D4169-14, ASTM F1980-07, ISO 2233:2000)
    Bacterial EndotoxinsPerformed and compliant (AAMI/ANSI ST72)
    Pyrogen TestPerformed and compliant (United States Pharmacopeia 37, National Formulary 32, 2014 )

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    The document does not explicitly state the sample sizes used for each specific test described under ISO 7886-1, ISO 594-2, or the biocompatibility tests. It broadly mentions "A battery of tests was performed." Nor does it specify the country of origin of the data or whether the tests were retrospective or prospective. It is implied these were prospective tests conducted on manufactured units of the Merit Syringe.

    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)

    This information is not provided. The compliance is based on meeting the established acceptance criteria of recognized consensus standards (ISO standards) and FDA guidance, rather than ground truth established by human experts in the context of diagnostic interpretation.

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

    Not applicable. The tests are based on objective measurements and compliance with specified standards, not on human interpretation requiring adjudication.

    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 device is a piston syringe, not an AI-assisted diagnostic tool.

    6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done

    Not applicable. This device is a physical medical device (syringe), not an algorithm. The performance evaluation is based on bench testing and material compatibility, which is analogous to "standalone" performance for a physical device.

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

    The "ground truth" for the device's performance is defined by the acceptance criteria specified within the referenced international consensus standards and FDA guidance documents (e.g., ISO 7886-1, ISO 594-2, ISO 10993 series). Compliance means the device's physical and biological properties meet these pre-defined, objectively measurable standards.

    8. The sample size for the training set

    Not applicable. There is no "training set" as this is a physical device undergoing performance and biocompatibility testing, not a machine learning algorithm.

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

    Not applicable. There is no training set mentioned for this type of device submission.

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    K Number
    K171362
    Device Name
    Merit Syringe
    Date Cleared
    2017-08-07

    (90 days)

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

    Merit Syringe

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

    The Merit Syringe is used to inject fluids into, or withdraw fluids from, the body.

    Device Description

    The Merit Syringe contains a calibrated hollow barrel into which is inserted a closely fitted, ratcheted plunger, and tip or seal. The barrel contains an ISO 594-2 compliant fixed male luer connector, which is compatible with ISO 594-2 compliant female luer hubs.

    AI/ML Overview

    The provided text describes the performance testing of the Merit Syringe, a medical device. Here's a breakdown of the requested information based on the text:

    1. A table of acceptance criteria and the reported device performance

    Acceptance Criteria (from ISO 7886-1)Reported Device Performance
    CleanlinessComplies with ISO 7886-1
    Limits for acidity or alkalinityComplies with ISO 7886-1
    Limits for extractable metalsComplies with ISO 7886-1
    LubricantComplies with ISO 7886-1
    Tolerance on Graduated Capacity (based on graduation scale)Complies with ISO 7886-1
    Tolerance on Graduated Capacity (based on audible/tactile use)Complies with ISO 7886-1
    Graduated ScaleComplies with ISO 7886-1
    BarrelComplies with ISO 7886-1
    Piston/Plunger AssemblyComplies with ISO 7886-1
    NozzleComplies with ISO 7886-1
    Performance – Freedom from air and liquid leakage past pistonComplies with ISO 7886-1
    Acceptance Criteria (from ISO 594-2)Reported Device Performance
    GaugingComplies with ISO 594-2
    Liquid leakageComplies with ISO 594-2
    Air leakageComplies with ISO 594-2
    Separation forceComplies with ISO 594-2
    Unscrewing torqueComplies with ISO 594-2
    Ease of assemblyComplies with ISO 594-2
    Resistance to overridingComplies with ISO 594-2
    Stress crackingComplies with ISO 594-2
    Biocompatibility (from ISO 10993 series and other standards)Reported Device Performance
    CytotoxicityComplies with ISO 10993 series
    SensitizationComplies with ISO 10993 series
    IrritationComplies with ISO 10993 series
    Acute Systemic ToxicityComplies with ISO 10993 series
    PyrogenicityComplies with USP 39, NF 34,
    HemolysisComplies with ASTM F756-08:2013
    Sterilization (Ethylene Oxide)Complies with ISO 11135:2014, ISO 10993-7:2008, AAMI TIR 28:2009
    Packaging (Terminally Sterilized Medical Devices)Complies with ISO 11607-1:2006, ASTM D4169-14: 2014, ASTM F1980-07:2007, ISO 2233:2000

    Reported Device Performance Summary: The device "met the standards' established acceptance criteria for the device". The text explicitly states, "Results of the testing demonstrate that the subject device met the acceptance criteria sufficient for its intended use."

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    The document does not explicitly state the sample size used for the test set for performance or biocompatibility testing. It only refers to a "battery of tests" being performed. Data provenance (country of origin, retrospective/prospective) is also not specified.

    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)

    This information is not applicable to this type of device and study. The testing described involves objective, standardized measurements against recognized consensus standards for physical, chemical, and biological properties of a piston syringe, not subjective interpretation by human experts.

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

    This information is not applicable. Adjudication methods are typically used in studies involving human interpretation or subjective assessments, often in clinical trials or diagnostic studies. The performance testing of the Merit Syringe involves objective measurements against predefined criteria.

    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

    A multi-reader multi-case (MRMC) comparative effectiveness study was not done. This type of study relates to the evaluation of diagnostic algorithms or AI tools, often in imaging, which is not relevant to the Merit Syringe.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    A standalone performance evaluation was done, but it refers to the performance of the syringe itself, not an algorithm. The testing described (bench testing, biocompatibility, sterilization, packaging) assesses the device's inherent properties and adherence to standards without human intervention influencing the device's function.

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

    The "ground truth" for the performance testing of the Merit Syringe was established by FDA recognized consensus standards (e.g., ISO 7886-1, ISO 594-2, ISO 10993 series, ASTM standards, USP). These standards define objective, measurable criteria for the various aspects of the syringe's function and safety.

    8. The sample size for the training set

    This information is not applicable. The Merit Syringe is a physical medical device, not an AI/machine learning algorithm that requires a "training set."

    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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