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510(k) Data Aggregation

    K Number
    K201356
    Date Cleared
    2021-02-12

    (267 days)

    Product Code
    Regulation Number
    868.5140
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Plastic LOR Syringe is intended for use in conjunction with an epidural needle, to verify the needle tip placement in the epidural space by the loss of Resistance technique, it will be filled with air and/or saline during use. The loss of Resistance Syringe is not intended for injection or aspiration. The syringe will be sold sterile individually packaged, and as part of a sterile kit.

    Device Description

    The Plastic LOR syringe is a piston syringe of three pieces. It consists of barrel, plunger and piston. The barrel is available with Luer slip, NRFit lock, NRFit Slip male connector. The Plastic LOR syringe is provided in combinations of four connectors and four syringe capacities (5ml, 7ml, 10ml, 20ml). The device is a sterile finished disposable device, supplied sterile to the end user and non-sterile will be supplied to Anesthetic Conduction Kit manufacturers to be sterile and packaged into kit. The Plastic LOR syringe is a single use device which will be supplied as sterile individually packaged and the non-sterile bulk packed. The sterilized by Ethylene Oxide Gas to achieve a SAL of 10° and supplied sterility maintenance package which could maintain the sterility of the device during the s helf life of five years.

    AI/ML Overview

    This document is a 510(k) Summary for a Plastic LOR Syringe. The purpose of this summary is to demonstrate that the device is substantially equivalent to legally marketed predicate devices.

    Here's the breakdown of the acceptance criteria and the study information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria are primarily derived from various ISO and ASTM standards for syringes, neuraxial, and Luer connectors, as well as biocompatibility and sterilization standards. The reported device performance indicates compliance with these standards.

    Acceptance Criteria CategorySpecific Standard/ClauseReported Device Performance
    Physical/MechanicalClause 5 of ISO 7886-1:2017 (General requirements)Conforms to requirements
    Clause 6 of ISO 7886-1:2017 (Extraneous matter)Conforms to requirements
    Clause 7 of ISO 7886-1:2017 (Lubricant)Conforms to requirements
    Clause 8 of ISO 7886-1:2017 (Tolerance on graduated capacity)Conforms to requirements
    Clause 9 of ISO 7886-1:2017 (Graduated scale)Conforms to requirements
    Clause 10 of ISO 7886-1:2017 (Barrel)Conforms to requirements
    Clause 11 of ISO 7886-1:2017 (Piston stopper/plunger assembly)Conforms to requirements
    Clause 12 of ISO 7886-1:2017 (Nozzle)Conforms to requirements
    Clause 13 of ISO 7886-1:2017 (Performance)Conforms to requirements
    Neuraxial Small-Bore ConnectorClause 5 of ISO 80369-6:2016 (Dimensional requirements)Conforms to requirements
    Clause 6.1 of ISO 80369-6:2016 (Fluid leakage)Conforms to requirements
    Clause 6.2 of ISO 80369-6:2016 (Sub-atmospheric pressure air leakage)Conforms to requirements
    Clause 6.3 of ISO 80369-6:2016 (Stress cracking)Conforms to requirements
    Clause 6.4 of ISO 80369-6:2016 (Resistance to separation from axial load)Conforms to requirements
    Clause 6.5 of ISO 80369-6:2016 (Resistance to separation from unscrewing)Conforms to requirements
    Clause 6.6 of ISO 80369-6:2016 (Resistance to overriding)Conforms to requirements
    Luer ConnectorClause 5 of ISO 80369-7:2016 (Dimensional requirements)Conforms to requirements
    Clause 6.1 of ISO 80369-7:2016 (Fluid leakage)Conforms to requirements
    Clause 6.2 of ISO 80369-7:2016 (Sub-atmospheric pressure air leakage)Conforms to requirements
    Clause 6.3 of ISO 80369-7:2016 (Stress cracking)Conforms to requirements
    Clause 6.4 of ISO 80369-7:2016 (Resistance to separation from axial load)Conforms to requirements
    Clause 6.5 of ISO 80369-7:2016 (Resistance to separation from unscrewing)Conforms to requirements
    Clause 6.6 of ISO 80369-7:2016 (Resistance to overriding)Conforms to requirements
    Sterile Barrier PackagingASTM F1886/F1886M-16 (Visual inspection)Maintained integrity
    ASTM F88/F88-15 (Seal strength)Maintained integrity
    ASTM F1929-15 (Dye penetration test)Maintained integrity
    Sterilization & Shelf LifeISO 10993-7:2008 (EO residue)EO ECH residue did not exceed the limit
    USP 39-NF 34 <85> (Bacteria Endotoxin Limit)Endotoxin limit did not exceed 2.15 EU/device
    Shelf Life Evaluation (Physical, Mechanical, Chemical, Package Tests on aging samples)Maintained performance during claimed shelf life (5 years)
    Biocompatibility(Implicitly based on ISO 10993 for indirect contact, <24 hours)No negative impacts from materials: Cytotoxicity (Passed), Sensitization (Passed), Intracutaneous reactivity (Passed), Acute Systemic Toxicity (Passed), Pyrogen (Passed), Particulate testing (Passed).
    Connector Compatibility(Implicitly tested against incompatible connectors)Would not be connected with incompatible connector (verified)

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

    The document does not specify the exact sample sizes for each non-clinical test (e.g., how many syringes were tested for fluid leakage, or how many samples for biocompatibility tests). It simply states that "Non clinical tests were conducted to verify that the proposed device met all design specifications."

    The data provenance is from non-clinical tests conducted by Jiangsu Caina Medical Co., Ltd. (the manufacturer). The country of origin of the testing data is presumably China, where the manufacturer is located. The tests are retrospective in the sense that they were performed to support the 510(k) submission for an already developed device.

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

    This information is not applicable as this is a non-clinical submission for a physical medical device (syringe), not an AI/software device that requires expert-established ground truth for a test set. The "ground truth" here is compliance with established international and national standards.

    4. Adjudication method for the test set

    This information is not applicable for the same reasons as point 3. Testing against standards does not typically involve adjudication in the way AI/software studies do.

    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, a multi-reader multi-case (MRMC) comparative effectiveness study was not done. This is a 510(k) submission for a physical medical device (Plastic LOR Syringe), which does not involve human readers or AI assistance.

    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 a physical medical instrument, not an algorithm.

    7. The type of ground truth used

    The "ground truth" for this submission is compliance with recognized consensus standards (ISO, ASTM, USP) for medical devices, materials, and sterilization, as well as the demonstration of substantial equivalence to predicate devices based on these tests.

    8. The sample size for the training set

    This information is not applicable as this is a physical medical device. There is no AI model or "training set" involved in its development or regulatory submission.

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

    This information is not applicable as there is no training set for this type of device.

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