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510(k) Data Aggregation

    K Number
    K212514
    Date Cleared
    2022-04-29

    (262 days)

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

    Safety Pen Needle for Single Use, Insulin Pen Needles

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

    The Safety Pen Needle for Single Use is intended for use with pen injector devices for the subcutaneous injection of insulin.

    The Insulin Pen Needle is intended for use with pen injector devices for the subcutaneous injection of insulin.

    Device Description

    The devices are provided in two types of configurations: Safety Pen Needle for Single Use and Insulin Pen Needle.

    The Safety Pen Needle for Single Use is intended for use with pen injector devices for the subcutaneous injection of insulin. It consists of a needle cap, needle hub, safety protective cover, self-destruction seat and sealed paper. The safety protective cover is manually activated to cover the needle immediately after use to minimize risk of accidental needle sticks.

    The Insulin Pen Needle is intended for use with pen injector devices for the subcutaneous injection of insulin. It consists of protective cap, needle tube, needle protective cover and sealed paper.

    AI/ML Overview

    The provided document describes a 510(k) premarket notification for a medical device, specifically Safety Pen Needles for Single Use and Insulin Pen Needles. It focuses on demonstrating substantial equivalence to a predicate device (K181447) rather than presenting a study for general acceptance criteria alone.

    Therefore, the response will be structured to address the acceptance criteria as derived from the comparative and standalone testing performed to establish substantial equivalence.

    Here's an analysis based on the provided text:


    1. Table of acceptance criteria and the reported device performance

    The document lists numerous non-clinical tests and standards that the proposed device was tested against. The acceptance criteria are implicit in compliance with these standards and the comparisons to the predicate device. The performance is stated as "complied with" or "met the requirements".

    Acceptance Criteria (Standard / Test)Reference Clause/StandardReported Device Performance
    Biocompatibility
    CytotoxicityISO 10993-5: 2009No cytotoxicity
    Irritation/Intracutaneous ReactivityISO 10993-10: 2010No intracutaneous reactivity
    SensitizationISO 10993-10: 2010No skin sensitization
    Systemic ToxicityISO 10993-11: 2017No systemic toxicity
    HemolysisASTM F756-17No Hemolysis
    PyrogenUSPNo Pyrogen
    Subacute ToxicityNot explicitly listed in table, but mentioned in textNo adverse effect
    Sterilization & Endotoxin
    EO Residue (EO, ECH)ISO 10993-7:2008Did not exceed limit
    Bacterial Endotoxins LimitUSPDid not exceed 20 EU/device
    Sterility Assurance Level (SAL)Not explicitly listed in table, but mentioned in text10^-6
    Packaging & Shelf Life
    Seal Integrity (Visual)ASTM F1886 / F1886M-16Deemed acceptable
    Seal StrengthASTM F88/F88M-15Complied with requirements
    Dye Penetration (Seal Leaks)ASTM F1929-15Complied with requirements
    Shelf Life (5 years)Physical, Mechanical, Chemical, Package TestsMaintain its performance
    Physical & Mechanical (General Needles)
    DimensionsISO 11608-2:2012 Cl. 4.2, ISO 9626:2016 Cl. 5.6Complied with requirements
    Flow RateISO 11608-2:2012 Cl. 4.3Complied with requirements
    Bond (Hub & Needle Tube)ISO 11608-2:2012 Cl. 4.4, ISO 7864:2016 Cl. 4.12Complied with requirements
    Needle PointsISO 11608-2:2012 Cl. 4.5, ISO 7864:2016 Cl. 4.11Complied with requirements
    Freedom from DefectsISO 11608-2:2012 Cl. 4.6Complied with requirements
    LubricationISO 11608-2:2012 Cl. 4.7Complied with requirements
    Dislocation of Measuring PointISO 11608-2:2012 Cl. 4.8Complied with requirements
    Functional Compatibility with Pen SystemsISO 11608-2:2012 Cl. 4.9Complied with requirements
    Ease of Assembly/DisassemblyISO 11608-2:2012 Cl. 4.10Complied with requirements
    CleanlinessISO 7864:2016 Cl. 4.3, ISO 9626:2016 Cl. 5.3Complied with requirements
    Acidity/AlkalinityISO 7864:2016 Cl. 4.4, ISO 9626:2016 Cl. 5.4Complied with requirements
    Extractable MetalsISO 7864:2016 Cl. 4.5Complied with requirements
    Size DesignationISO 7864:2016 Cl. 4.6, ISO 9626:2016 Cl. 5.5Complied with requirements
    Color CodingISO 7864:2016 Cl. 4.7Complied with requirements
    Needle HubISO 7864:2016 Cl. 4.8Complied with requirements
    Needle CapISO 7864:2016 Cl. 4.9Complied with requirements
    Needle TubeISO 7864:2016 Cl. 4.10Complied with requirements
    Lumen PatencyISO 7864:2016 Cl. 4.13Complied with requirements
    Surface Finish & AppearanceISO 9626:2016 Cl. 5.2Complied with requirements
    StiffnessISO 9626:2016 Cl. 5.8Complied with requirements
    Resistance to BreakageISO 9626:2016 Cl. 5.9Complied with requirements
    Resistance to CorrosionISO 9626:2016 Cl. 5.10Complied with requirements
    Particulate TestingUSPComplied with requirements
    Specific Safety Pen Needle Features
    Safety Feature PerformanceISO 23908:2011 & FDA GuidanceMet pre-established criteria
    Safety Feature Activation Forces(Compared to Predicate)Average at 3.71N (Predicate: 3.73N)

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

    The document does not specify the exact sample sizes for each test in the acceptance criteria. It broadly states "Non-clinical tests were conducted..." and "Physical, Mechanical, and Chemical testing listed in following table were performed on the proposed device."
    Regarding data provenance, the manufacturer is Berpu Medical Technology Co., Ltd. in Wenzhou, Zhejiang, China. Therefore, the data provenance is China, and the data is prospective as it involves direct testing of the proposed devices.

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

    This section is not applicable as the document describes non-clinical laboratory and performance testing for a medical device (pen needles), not a diagnostic algorithm requiring expert ground truth for interpretation of images or other data. The "ground truth" here is defined by compliance with established international and ASTM standards.

    4. Adjudication method for the test set

    This section is not applicable for the same reasons as point 3. The evaluation is based on objective measurements against specified standard criteria, not subjective expert judgment 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

    This section is not applicable. The device is a physical medical device (pen needle), not an AI-powered diagnostic tool, and therefore, no MRMC study or AI assistance evaluation was performed or is relevant.

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

    This section is not applicable as the device is a physical medical instrument, not an algorithm or software. The non-clinical tests described are "standalone" in the sense that they evaluate the device's intrinsic properties against standards, without human interaction influencing the core performance metrics being measured (e.g., flow rate, bond strength).

    7. The type of ground truth used

    The "ground truth" for the non-clinical tests and the product's performance is established by international and national standards (e.g., ISO, ASTM, USP) and the specifications derived from these standards. For example, the criteria for cytotoxicity or sterility assurance level (SAL) are defined by the respective ISO and USP standards. The "pre-established criteria" mentioned for the simulated clinical study and safety feature test would also fall under this category, likely derived from the relevant standards (ISO 23908:2011) and FDA guidance.

    8. The sample size for the training set

    This section is not applicable. The document describes the testing of a physical medical device. There is no "training set" in the context of an AI/ML algorithm. The training in device manufacturing typically refers to process validation and quality control, not data training.

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

    This section is not applicable for the same reason as point 8; there is no training set mentioned in the context of this device's approval process.


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