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510(k) Data Aggregation
(28 days)
Praxiject 0.9% NaCl
The Praxiject™ 0.9% NaCl prefilled syringe with 0.9% Sodium Chloride Injection, USP, is intended only for flushing vascular access devices. May be placed on a sterile field.
The Praxiject™ family of 0.9% NaCl prefilled syringes marketed in the U.S.A. includes the following models: 37043US (3 mL/5 cc), 3704US (5 mL/5 cc), 37053US (3 mL/10 cc), 37055 US (5 mL/10 cc), 3705CUS (10 mL/10 cc), 3705-1US (10 mL/10 cc) and 3706US (20 mL/20 cc). These devices are single use plastic piston syringes with a Luer lock connection fitting, prefilled to labeled volume with 0.9% Sodium Chloride Injection USP, with no preservatives (normal saline), and capped with a plastic tip cap. Model 3705-1US (10 mL/10 cc) is individually packaged in a heat-sealed foil pouch, all other models are individually packaged in a heat-sealed peel pouch. All Praxiject™ 0.9% NaCl prefilled syringes are terminally sterilized by gamma irradiation.
The provided document is a 510(k) Pre-Market Notification for a medical device called Praxiject™ 0.9% NaCl, which is a prefilled saline flush syringe. The purpose of this notification is to demonstrate that the modified device is substantially equivalent to legally marketed predicate devices.
The document does not describe a study involving an AI/ML device, a "test set" of data, or "ground truth" as typically understood in the context of evaluating AI/ML performance. Instead, it details the analytical and performance testing conducted for a physical medical device to ensure its safety and effectiveness.
Therefore, many of the requested categories (2, 3, 4, 5, 6, 7, 8, 9) are not applicable to this document as they are specific to AI/ML device evaluation.
However, I can extract information related to acceptance criteria and device performance based on the non-clinical testing summary.
1. A table of acceptance criteria and the reported device performance
The document provides a comprehensive table of "Device Specification," "Standard," and "Acceptance Criteria" under the "Summary of Non-Clinical Testing" section. The "reported device performance" is implicitly stated as meeting these acceptance criteria, as the conclusion states, "The conclusions drawn from the non-clinical testing demonstrate that the modified Praxiject™ 0.9% NaCl prefilled syringe, is as safe, as effective, and performs as well as or better than the legally marketed primary predicate device." This implies all listed acceptance criteria were met.
Here is a summary of the acceptance criteria:
Device Specification | Standard | Acceptance Criteria |
---|---|---|
Piston Syringe Testing (Each production lot) | ||
Design and Performance Requirements | ISO 7886-1; ISO 80369-7 (ISO 594-1 and ISO 594-2) | Conformity to standards and device specifications |
Finished Device Testing (Each production lot) | ||
Appearance of Solution | USP / Visual inspection | Clear and colorless; Free of visible foreign solid particles |
Solution Volume | ISO 7886-1, USP | 3 mL in 5 cc syringe: 3.0–3.4 mL |
3 mL in 10 cc syringe: 3.0-3.6 mL | ||
5 mL in 5 cc syringe: 5.0-5.6 mL | ||
5 mL in 10 cc syringe: 5.0-6.0 mL | ||
10 mL in 10 cc syringe: 10.0–11.0 mL | ||
20 mL in 20 cc syringe: 20.0-22.0 mL | ||
Assay | USP Sodium Chloride Injection | 0.855 - 0.945% (w/v) |
Identification | USP Sodium and Chloride | Meets USP requirements |
Bacterial Endotoxins | USP , USP | ≤ 0.5 USP EU/mL |
Particulate Matter | USP | Particles ≥ 10 µm: ≤ 6000/syringe; |
Particles ≥ 25 µm: ≤ 600/syringe | ||
pH | USP | 4.5 - 7.0 |
Elemental Impurities | USP and USP (Class I elements) | Arsenic: |
Syringe Closure Integrity | ISO 7886-1, ISO 594-2 (Adapted solution leakage test) | No damage, no leakage past piston and syringe tip cap |
Pouch Integrity | ASTM D3078 (Vacuum bubble emissions test) | No stream of bubbles; no leaks |
Sterility and Shelf-life Testing (Design Verification and Validation) | ||
Sterility of Solution and Syringe Exterior | USP | Sterile |
Sterilization Method Validation | ISO 11137-1, ISO 11137-2, USP (Terminal sterilization by gamma radiation) | SAL 10-6 |
Shelf-life (Stability Study) | FDA Guidance: Shelf Life of Medical Devices (1991); FDA Guidance: Q1D Bracketing and Matrixing Designs for Stability Testing of New Drug Substances and Products (2003) | Device specifications must be maintained for the labeled shelf life |
Distribution Simulation Testing (Design Verification and Validation) | ||
Device & Package Integrity | ASTM D4169 (Distribution Cycle 13, Assurance Level II); ISO 11607-1; ASTM F1886 (Visual seal integrity verification); ASTM D3078 (Vacuum bubble emissions test); ISO 7886-1 and ISO 594-2 (Syringe and tip cap integrity verification) | No structural damage to shipping carton; |
Pouch/seal integrity - No seal defects; no stream of bubbles and no leaks during vacuum bubble emissions testing; | ||
Syringe integrity - No critical damage, no leaks past syringe cap or gasket; | ||
Luer lock (tip cap) connection - No cracks, no leaks | ||
Biocompatibility Testing (Design Verification and Validation) | ||
Biological Evaluation | ISO 10993-1; FDA Guidance: Use of International Standard ISO 10993-1, Biological evaluation of medical devices Part 1: Evaluation and testing within a risk management process (2020) | Compliant process and evaluation for external communicating devices intended for indirect blood path contact with limited duration |
Chemical Characterization (Extractables/Leachables) | ISO 10993-18, ISO 10993-17 USP | Acceptable extractables/leachables profile; Negligible risk of health hazard |
Cytotoxicity | ISO 10993-5 | Non-cytotoxic |
Sensitization | ISO 10993-10 | Non-sensitizer |
Irritation | ISO 10993-23 | Non-irritant |
Hemolysis | ISO 10993-4 (ASTM F756) | Non-hemolytic |
Acute Systemic Toxicity | ISO 10993-11 | Non-toxic |
Pyrogenicity | ISO 10993-11 (USP ) | Non-pyrogenic |
2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
This information is not provided in a way that is applicable to an AI/ML "test set." The document describes non-clinical testing of a physical device. While specific sample sizes and testing methodologies are implied by the listed standards (e.g., ISO, ASTM, USP), the exact sample sizes for each test are not explicitly enumerated in this summary. Data provenance, in terms of country of origin or retrospective/prospective collection, is not relevant for this type of device submission.
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" and "experts" are terms used in the context of evaluating diagnostic AI/ML models. This document describes the physical and chemical testing of a medical device.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. This refers to methods for resolving discrepancies in expert interpretations, which is not relevant for physical device testing.
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 a type of study specifically for evaluating AI/ML diagnostic tools.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This refers to the standalone performance of an AI/ML algorithm.
7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)
Not applicable. The "ground truth" for this device's performance is objective measurements against established international and USP standards for product quality, safety, and performance (e.g., pH, sterility, particle count, leakage, biocompatibility).
8. The sample size for the training set
Not applicable. This concept pertains to AI/ML model development.
9. How the ground truth for the training set was established
Not applicable. This concept pertains to AI/ML model development.
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(162 days)
Praxiject 0.9% NaCl
The Praxiject™ 0.9% NaCl prefilled syringe with 0.9% Sodium Chloride Injection, USP, is intended only for flushing vascular access devices. May be placed on a sterile field.
The Praxiject™ 0.9% NaCl prefilled syringe is a single use plastic piston syringe with a Luer lock connection fitting, prefilled to labeled volume with 0.9% Sodium Chloride Injection, USP, with no preservatives (normal saline), and capped with a plastic tip cap. Each prefilled syringe is individually packaged in a heat-sealed pouch and terminally sterilized by gamma irradiation.
The provided text is a 510(k) summary for the Praxiject™ 0.9% NaCl prefilled syringe, a medical device. It describes the device, its intended use, and comparative non-clinical testing performed to demonstrate substantial equivalence to a predicate device.
Here's the information extracted from the document regarding acceptance criteria and the study that proves the device meets them:
1. A table of acceptance criteria and the reported device performance:
Test Methodology / Standard | Purpose | Acceptance Criteria | Results |
---|---|---|---|
Visual inspection of pouch seals per ASTM F1886 | To verify pouch seal integrity | No visible unsealed areas, channels/pathway across width of seal, tears/holes: Reject on detection. Undersealed areas, oversealed areas (hard/brittle seal), narrow seals: non defective seal width should be greater than 67% of nominal seal width. | Conforms |
Bubble emission test of pouch per ASTM D3078 | To verify the integrity of the product packaging (pouch) | No leaks (no bubbles emitted upon immersion, no fluid inside the package). | Conforms |
Visual inspection of prefilled syringe for damage | To ensure the prefilled syringe is not damaged in a way that would prevent its use | No critical damage (consistent with instructions for use); no leaks. | Conforms |
Test for liquid leakage and resistance of luer lock fitting | To ensure the prefilled syringe is adequately sealed | No leaks; no cracks. | Conforms |
Test for integrity of printed label per ASTM F2250 | To verify the integrity of the printed information is adequate for the intended use environment | Print must remain defined and legible, color must not lighten, ink must not run (Slight smudging of ink or transfer to swab is allowable). | Conforms |
Test of formulation per Sodium Chloride Injection USP monograph: | To verify formulation of the Sodium Chloride solution meets the USP requirements | Assay of Sodium Chloride: 0.855 to 0.945% NaCl | Conforms |
- pH per USP | pH: 4.5 to 7.0 | Conforms | |
- Identification of Sodium and Chloride per USP | Identification: Successful identification | Conforms | |
- Particulate matter per USP | Particulate matter: ≥ 10μm: ≤ 6000 part/syringe; ≥ 25μm: ≤ 600 part/syringe | Conforms | |
- Bacterial Endotoxins per USP | Bacterial Endotoxins: ≤ 0.5 EU/mL | Conforms | |
- Elemental Impurities (Heavy Metals) per USP/ (Class I elements) | Elemental Impurities: Arsenic: ≤ 1.5μg/g; Cadmium: ≤ 0.2μg/g; Mercury: ≤ 0.3μg/g; Lead: ≤ 0.5μg/g | Conforms | |
- Iron per USP | Iron: ≤ 2ppm | Conforms | |
Distribution cycle (Transport) Validation per ASTM D4169, Distribution Cycle 13 | To ensure the packaging maintains product integrity under anticipated shipping and handling conditions | Packaging and syringe integrity per ISO 11607-1 | Conforms |
Sterilization Validation | To establish the minimum irradiation dose required to render the product sterile | 10-6 SAL per ISO 11137-2 | Conforms |
2. Sample size used for the test set and the data provenance:
The document does not explicitly state the specific sample sizes used for each individual test. It lists "non-clinical testing" as the study type. The reference to standards like ASTM and USP monographs implies that the testing was performed on physical samples of the device and its packaging.
- Data Provenance: The tests are described as "non-clinical testing" performed by MedXL Inc. The country of origin of the data is not specifically stated, but the manufacturer's address is in Pointe-Claire, Quebec, Canada. The data is retrospective as it was performed prior to the submission of the 510(k).
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. The studies performed are non-clinical (physical and chemical tests) and do not involve human interpretation or the establishment of ground truth by experts in a clinical context. The "ground truth" is determined by the results of the standardized tests against their defined acceptance criteria.
4. Adjudication method for the test set:
Not applicable. This concept applies to studies involving human interpretation or subjective assessments, which is not the case for these non-clinical tests.
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 a non-clinical device (prefilled saline syringe) and does not involve AI assistance, human readers, or clinical effectiveness studies in this context.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
Not applicable. This device does not involve algorithms or AI.
7. The type of ground truth used:
The "ground truth" for the non-clinical tests is established by pre-defined, objective acceptance criteria derived from recognized industry standards (ASTM, ISO) and pharmaceutical monographs (USP). For example, the definition of an acceptable seal, specific chemical concentrations, or maximum particulate matter levels.
8. The sample size for the training set:
Not applicable. This device is not an AI/ML device, so there is no training set in the conventional sense.
9. How the ground truth for the training set was established:
Not applicable. As there is no training set, this question is not relevant.
Ask a specific question about this device
(251 days)
Praxiject 0.9% NaCl
The Praxiject™ 0.9% NaCl prefilled syringe with 0.9% Sodium Chloride Injection, USP, is intended only for flushing vascular access devices. May be placed on a sterile field.
The Praxiject™ 0.9% NaCl prefilled syringe is a single use plastic piston syringe with a Luer lock connection fitting, prefilled to labeled fill volume with 0.9% Sodium Chloride Injection, USP, with no preservatives (normal saline), and capped with a plastic tip cap. Each prefilled syringe is individually packaged in a plastic peel pouch and terminally sterilized by gamma irradiation.
This document is a 510(k) Pre-market Notification for a medical device called Praxiject™ 0.9% NaCl, which is a prefilled syringe. This type of submission focuses on demonstrating substantial equivalence to a legally marketed predicate device, rather than proving the device meets specific performance criteria through clinical studies or AI algorithm validation studies.
Therefore, many of the requested details about acceptance criteria, study types, sample sizes, and expert ground truth are not applicable to this document as it pertains to a traditional medical device (a prefilled syringe) and not an AI/ML-driven diagnostic or treatment device.
Here's an analysis based on the provided document:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly present "acceptance criteria" in the context of an AI algorithm's performance metrics (e.g., sensitivity, specificity, AUC). Instead, it presents performance standards and results for the physical and chemical characteristics of the prefilled syringe.
Device / Performance Characteristic | Performance Standard | Reported Device Performance (Results) |
---|---|---|
Solution | Sodium Chloride Injection, USP 39-NF34 | Conforms |
Plastic syringe | ISO 7886-1, 0 mL average syringe induced reflux | Conforms |
Biocompatibility - Hemolysis | ISO 10993-4 (ASTM F756) | Non-hemolytic |
Biocompatibility - Cytotoxicity | ISO 10993-5 | Non-cytotoxic |
Biocompatibility - Sensitization | ISO 10993-10 | Non-sensitizer |
Biocompatibility - Irritation/Intracutaneous reactivity | ISO 10993-10 | Non-irritant |
Biocompatibility - Acute system toxicity | ISO 10993-11 | No systemic toxicity |
Biocompatibility - Material—mediated pyrogenity | ISO 10993-11 (USP ) | No material mediated response observed |
Biocompatibility - Bacterial Endotoxins | USP and USP (≤ 0.5 EU/mL) | Conforms |
Biocompatibility - Chemical characterization | ISO 10993-18 | Acceptable extractables/leachables profile |
Biocompatibility - Particulate matter | USP | Conforms |
Shelf life | ISO 11607-1 | 2 years (mentioned in comparison table, not directly in performance results table but implied by "evaluated using the recognized consensus standard") |
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 document describes testing for a physical medical device (syringe), not an AI algorithm. The "test set" would refer to samples of the manufactured syringes and their components, tested in a laboratory setting according to the listed standards. There is no mention of "country of origin of the data" or "retrospective/prospective" as these pertain to clinical data for AI/ML validation.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Not applicable. Ground truth in the context of this document refers to established standards and laboratory measurements for chemical and physical properties, not expert clinical interpretation. The "experts" would be laboratory technicians and chemists performing the tests according to standardized protocols.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable. This concept pertains to resolving discrepancies among expert readers in AI/ML validation studies. For direct physical and chemical testing, the results are typically objectively measured against pre-defined specifications in the performance 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 a traditional medical device (syringe), not an AI/ML system, so such a study would not be performed.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
- Not applicable. This is a physical device, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- The "ground truth" for this device's performance is established by conformance to recognized consensus standards (e.g., USP, ISO standards) and laboratory testing methods that define acceptable ranges and limits for physical, chemical, and biological properties. This is an objective, standardized ground truth based on scientific principles and established testing methodologies.
8. The sample size for the training set
- Not applicable. This is a physical medical device. There is no "training set" in the context of this 510(k) submission.
9. How the ground truth for the training set was established
- Not applicable. As there is no training set for an AI algorithm, this question does not apply.
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