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510(k) Data Aggregation

    K Number
    K243936
    Manufacturer
    Date Cleared
    2025-04-03

    (104 days)

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

    StaClear Syringe (SC250AN); StaClear Syringe (SC250LS); StaClear Syringe (SC250LL)

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

    The StaClear Syringe is intended to inject fluids into, or withdraw fluids from, the body. The StaClear Syringe is indicated for intravitreal use.

    Device Description

    The StaClear Syringe is a single-use piston syringe intended for use by healthcare professionals for general-purpose fluid aspiration/injection. Its operation is manual. The StaClear Syringe is single use only, non-toxic, non-pyrogenic, and sterilized by ethylene oxide gas. It uses standard syringe components with a low-particulate gas plasma crosslinked silicone coating called TriboLink-Si. The StaClear Syringe is suitable for ophthalmic use.

    The StaClear Syringe is offered in the following configurations:

    • SC250AN – Consisting of a 0.25 mL graduated barrel, plunger, plunger stopper, needle, needle shield, and plunger cap.
    • SC250LS – Consisting of a 0.25 mL graduated barrel with an ISO 80369-7-compliant luer-slip connector, plunger, and plunger stopper.
    • SC250LL – Consisting of a 0.25 mL graduated barrel with an ISO 80369-7-compliant luer-lock connector, plunger, and plunger stopper.
    AI/ML Overview

    The provided document is an FDA 510(k) clearance letter for the StaClear Syringe, which is a medical device, not an AI/ML algorithm. Therefore, many of the requested fields, such as "number of experts used to establish the ground truth," "adjudication method," "MRMC comparative effectiveness study," "standalone algorithm performance," "type of ground truth," and information about training sets, are not applicable to this type of device and therefore not present in the document.

    The document primarily focuses on demonstrating substantial equivalence to a predicate device through adherence to established performance standards for syringes.

    Here's the information that can be extracted from the provided text regarding acceptance criteria and performance:

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

    The document lists various ISO and USP standards as the basis for performance evaluation. The "Acceptance Criteria" are implied to be compliance with these standards, and the "Reported Device Performance" is stated as "Identical" or "Compliant" with these standards.

    Attribute/TestAcceptance Criteria (Implied)Reported Device Performance
    Syringe Performance (ISO 7886-1)Compliance with ISO 7886-1:2017Identical to predicate; Device maintains performance per ISO 7886-1 after 5-years of aging.
    - CleanlinessPassIdentical
    - Acidity and AlkalinityPassIdentical
    - Extractable MetalsIOL limits per ISO 11979-5Identical
    - LubricantPassIdentical
    - Tolerance on GraduationsPassIdentical
    - Stopper DetachmentPassIdentical
    - Dead SpacePassIdentical
    - Air and Liquid Leakage Past StopperPassIdentical
    - Plunger ForcePassIdentical
    - Fit of StopperPassIdentical
    Needle Performance (SC250AN only) (ISO 7864 & ISO 9626)Compliance with ISO 7864:2016 & ISO 9626:2016Identical to predicate; Device maintains performance per ISO 7864, ISO 9626 after 5-years of aging.
    - CleanlinessPassIdentical
    - Acidity and AlkalinityPassIdentical
    - Extractable MetalsIOL limits per ISO 11979-5Identical
    - Tolerance on LengthPassIdentical
    - Tube DefectsPassIdentical
    - LubricantPassIdentical
    - Point DefectsPassIdentical
    - Needle Penetration ForcePassIdentical
    - Bond Between Tube and HubPassIdentical
    - Patency of LumenPassIdentical
    - MaterialsPassIdentical
    - Surface FinishPassIdentical
    - Size DesignationPassIdentical
    - Outside DiameterPassIdentical
    - StiffnessPassIdentical
    - Resistance to BreakagePassIdentical
    - Resistance to CorrosionPassIdentical
    Luer Connector Performance (SC250LS and SC250LL only) (ISO 80369-7)Compliance with ISO 80369-7:2021Compliant with established performance standards; Device maintains performance per ISO 80369-7 after 5-years of aging.
    - MaterialsPassCompliant
    - Dimensional RequirementsPassCompliant
    - Fluid LeakagePassCompliant
    - Air LeakagePassCompliant
    - Stress CrackingPassCompliant
    - Separation ForcePassCompliant
    Luer-Lock only (ISO 80369-7)Compliance with ISO 80369-7:2021Compliant with established performance standards.
    - Unscrewing TorquePassCompliant
    - Resistance to OverridingPassCompliant
    Particulate TestingCompliance with USP & USPIdentical to predicate; Device performs as intended.
    - Particulate Matter in Injections (USP )PassIdentical
    - Particulate Matter in Ophthalmic Solutions (USP )PassIdentical
    BiocompatibilityCompliance with ISO 10993-1 for external communicating device with prolonged tissue contactBiocompatible for intended use.
    SterilitySterilized to SAL 10⁻⁶; Endotoxin per USP with IOL limits; Sterility per USPSterilized to SAL 10⁻⁶; Endotoxin levels meet IOL limits; Device maintains sterility per USP after 5-years of aging.
    Shelf LifeMaintain performance and sterility for 5 yearsTesting demonstrates performance and sterility maintained over 5 years after accelerated aging.
    PackagingCompliance with ISO 11607-1:2019 for sterile barrierCompliant with established requirements per ISO 11607-1:2019. (For Tyvek Pouch packaging)
    - Sterile Barrier IntegrityPass (e.g., using bacterial aerosol followed by sterility tests per USP )Maintained.

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

    The document does not specify the sample sizes used for testing each attribute. The data provenance (country of origin, retrospective/prospective) is also not provided. The testing is described as "non-clinical testing" and "performance testing performed as per the design control system," suggesting in-house, prospective testing.

    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. This is a physical medical device, not an AI/ML algorithm requiring expert ground truth for image interpretation or diagnosis. The "ground truth" for the device's performance is objective measurements against established engineering and biocompatibility standards.

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

    Not applicable. This is a physical medical device, not an AI/ML algorithm requiring adjudication of interpretations.

    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 physical medical device and does not involve AI assistance for human readers.

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

    Not applicable. This is a physical medical device, not an algorithm. The "standalone" performance refers to the device's adherence to specified standards in direct testing.

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

    The "ground truth" for this device's performance is adherence to recognized international and national standards for medical devices, specifically:

    • ISO standards (e.g., ISO 7886-1, ISO 7864, ISO 9626, ISO 80369-7, ISO 10993-1, ISO 11607-1) which define performance characteristics, materials, and testing methodologies.
    • USP standards (e.g., USP , USP , USP , USP ) which define testing for particulate matter, sterility, and endotoxins.
    • ASTM standards (e.g., ASTM D4169, ASTM F1980) for packaging and accelerated aging.

    These standards provide objective, measurable criteria.

    8. The sample size for the training set

    Not applicable. This is a physical medical device and does not involve a training set as would an AI/ML algorithm.

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

    Not applicable. This is a physical medical device and does not involve a training set.

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    K Number
    K200242
    Device Name
    StaClear Syringe
    Date Cleared
    2020-07-27

    (178 days)

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

    StaClear Syringe

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

    The StaClear Syringe is intended to inject fluids into, or withdraw fluids from, the body. The StaClear Syringe is indicated for intravitreal use.

    Device Description

    The StaClear Syringe is a single-use piston syringe consisting of a 0.25 mL graduated barrel, plunger, plunger stopper, needle, needle shield, and plunger cap. The needle is a 31-gauge needle, 5/16in in length, which is permanently attached to the syringe body. It is intended for use by health care professionals for general purpose fluid aspiration/injection. Its operation is manual. The StaClear syringe is single use only, non-toxic, non-pyrogenic, and sterilized by ethylene oxide gas. The StaClear syringe is suitable for ophthalmic use.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and study information for the StaClear Syringe, based on the provided document:

    Acceptance Criteria and Device Performance

    Acceptance Criteria CategorySpecific Test/EvaluationAcceptance Criteria (Standard)Reported Device Performance
    Material/Physical PropertiesCleanlinessISO 7886-1:2017, ISO 7864:2016, ISO 9626:2016Met applicable requirements
    Acidity and AlkalinityISO 7886-1:2017, ISO 7864:2016, ISO 9626:2016Met applicable requirements
    Extractable MetalsExhaustive extraction, limits ≤ 0.2 µg/device (intraocular lenses)Met applicable requirements
    LubricantISO 7886-1:2017, ISO 7864:2016Met applicable requirements
    Tolerance on GraduationsISO 7886-1:2017Met applicable requirements
    Stopper DetachmentISO 7886-1:2017Met applicable requirements
    Dead SpaceISO 7886-1:2017Met applicable requirements
    Air and Liquid Leakage Past PlungerISO 7886-1:2017Met applicable requirements
    Plunger ForceISO 7886-1:2017Met applicable requirements
    Fit of StopperISO 7886-1:2017Met applicable requirements
    Tolerance on Length (needle)ISO 7864:2016Met applicable requirements
    Tube Defects (needle)ISO 7864:2016Met applicable requirements
    Point Defects (needle)ISO 7864:2016Met applicable requirements
    Needle Penetration ForceISO 7864:2016Met applicable requirements
    Bond between Tube and HubISO 7864:2016Met applicable requirements
    Patency of LumenISO 7864:2016Met applicable requirements
    Materials (needle)ISO 9626:2016Met applicable requirements
    Surface Finish (needle)ISO 9626:2016Met applicable requirements
    Size designation (needle)ISO 9626:2016Met applicable requirements
    Dimensions (needle)ISO 9626:2016Met applicable requirements
    Stiffness (needle)ISO 9626:2016Met applicable requirements
    Resistance to Breakage (needle)ISO 9626:2016Met applicable requirements
    Resistance to Corrosion (needle)ISO 9626:2016Met applicable requirements
    Particulate MatterParticulate Matter in InjectionsUSPMet applicable requirements
    Particulate Matter in Ophthalmic SolutionsUSPMet applicable requirements
    BiocompatibilityCytotoxicity (cell lysis/toxicity)ISO 10993-5No evidence of causing cell lysis or toxicity
    Sensitization (skin)ISO 10993-10Not considered a sensitizer
    Irritation, OcularISO 10993-15Not considered irritants to the ocular tissue of the rabbit
    Irritation, Intravitreal InjectionIntravitreal Injection Irritation testingNot considered inflammatory to intraocular tissues of the rabbit
    Intracutaneous ReactivityISO 10993-15No intracutaneous reactivity (no erythema and edema)
    Acute Systemic ToxicityISO 10993-11No mortality or evidence of systemic toxicity
    PyrogenicityISO 10993-11Not considered pyrogenic
    HemolysisASTM F756, ISO 10993-4Not considered hemolytic
    Chemical Characterization / Toxicological Risk AssessmentISO 10993-1, ISO 10993-2, ISO 10993-4, ISO 10993-5, ISO 10993-10, ISO 10993-11, ISO 10993-12, ISO 10993-17, ISO 10993-18Acceptable level of risk of systemic exposure to extractable compounds

    Study Information

    The document describes non-clinical bench testing and biocompatibility testing. It does not describe a study comparing human readers with and without AI assistance, nor does it describe a standalone algorithm-only performance study.

    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 numerical sample sizes for each test. For example, it lists "Cleanliness" as a test performed but does not quantify how many units were tested.
    • The data provenance is not specified beyond being "non-clinical bench testing" and "TriboFilm's design control system," implying internal testing by the manufacturer. No country of origin for test data is mentioned.

    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. This device is a medical product (syringe), and the evaluation involved bench testing and biocompatibility assessment, not interpretation of medical images or diagnostic tasks. As such, "ground truth" was established by adherence to recognized testing standards and methods, not expert consensus in a clinical diagnostic sense.

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

    • Not applicable for this type of device and testing. The tests performed are objective, quantitative measurements against established 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

    • No, a multi-reader multi-case (MRMC) comparative effectiveness study was not done. This device is a syringe, not an AI-powered diagnostic tool.

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

    • No, a standalone algorithm-only performance study was not done. This device does not involve an algorithm.

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

    • The "ground truth" for evaluating the StaClear Syringe against its acceptance criteria was based on:
      • International and National Standards: e.g., ISO 7886-1, ISO 7864, ISO 9626, ISO 10993 series, ASTM F756, USP , USP . These standards define acceptable performance limits and test methodologies.
      • Objective Measurements: Laboratory and material testing results.
      • Biological Endpoints: Observed responses in biocompatibility tests (e.g., absence of cell lysis, irritation, toxicity).

    8. The sample size for the training set

    • Not applicable. This device does not use machine learning or AI, so there is no training set.

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

    • Not applicable. As there is no training set, this question is irrelevant.
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