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510(k) Data Aggregation
(293 days)
Disposable Sterile Syringe with Safety Needle; Disposable Sterile Syringe with Needle; Disposable Sterile
The disposable sterile syringe with safety needle is intended for use in the aspiration of fluids for medical purpose. After withdrawal of the needle from the body, the attached needle safety shield can be manually activated to cover the needle immediately after use to minimize risk of accidental needle sticks.
The disposable sterile syringe with needle is intended for use the aspiration of fluids for medical purpose.
The disposable sterile syringe is a sterile luer lock or luer slip syringe which is intended to be used with a hypodermic needle for the aspiration and injection of fluids for medical purpose.
The disposable safety needles are intended to be used with a luer slip or luer lock syringe for aspiration and injection of fluids for medical purpose. After withdrawal of the needle from the body, the attached needle safety shield can be manually activated to cover the needle immediately after use to minimize risk of accidental needlestick.
Not Found
This document is a 510(k) clearance letter from the FDA for various disposable sterile syringes and safety needles. It does not contain information about the acceptance criteria or a study proving a device meets those criteria, as it is related to general medical devices (syringes and needles), not an AI/ML powered device.
Therefore, I cannot extract the requested information regarding acceptance criteria, device performance, study details, sample sizes, ground truth establishment, or expert qualifications because this information is not present in the provided text.
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(161 days)
Sterile Syringe with Safety Needle for Single Use, Sterile Syringe with Needle for Single Use, Sterile
Sterile Syringe with Safety needle for Single Use is intended for use in the aspiration of fluids for medical purpose. After withdrawal of the needle from the body, the attached needle safety mechanism can be manually activated to cover the needle immediately after use to minimize risk of accidental needlesticks.
Sterile Syringe with needle for Single Use is intended for use in the aspiration of fluids for medical purpose.
Sterile Syringe for Single Use is a sterile luer slip syringe which is intended to be used with a hypodermic needle for the aspiration and injection of fluids for medical purpose.
Sterile Safety Needle for Single Use is intended to be used with a luer slip syringe for aspiration and injection of fluids for medical purpose. After withdrawal of the needle from the body, the attached needle safety mechanism can be manually activated to cover the needle immediately after use to minimize risk of accidental needlesticks.
Sterile Needle for Single Use is intended to be used with a luer slip or luer lock syringe for aspiration and injection of fluids for medical purpose.
Not Found
I'm sorry, but this document does not contain the information requested regarding acceptance criteria and a study proving the device meets those criteria.
This document is an FDA 510(k) clearance letter for various types of syringes and needles. It confirms that the devices are substantially equivalent to legally marketed predicate devices and mentions the indications for use.
It does not include any details about:
- A table of acceptance criteria and reported device performance.
- Sample sizes for test sets or their provenance.
- The number or qualifications of experts for ground truth establishment.
- Adjudication methods.
- Results of a multi-reader multi-case (MRMC) study or effect sizes of AI assistance.
- Standalone algorithm performance.
- Type of ground truth used.
- Training set sample size or how its ground truth was established.
This type of information would typically be found in the 510(k) submission itself (which is not provided here) or a more detailed performance study report, not in the clearance letter summarizing the FDA's decision.
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(129 days)
Sterile Syringe With Safety Needle
The Sterile Syringe with Safety Needle is intended for use in the aspiration of fluids for medical purpose. After withdrawal of the needle from the body, the attached needle safety shield can be manually activated to cover the needle immediately after use to minimize risk of accidental needle sticks.
The Sterile Disposable Syringe with Safety Needle is intended for manual and single use only. It consists of a hypodermic needle with a safety sheath attached to the needle hub and a luer slip or luer lock syringe. The subject device is available in a variety of syringe volumes and needle sizes. The safety sheath is manually activated to cover the needle immediately after use to minimize risk of accidental needle sticks.
The provided FDA 510(k) summary (K211753) is for a Sterile Syringe with Safety Needle. This document outlines the premarket notification for a Class II medical device, comparing it to a predicate device (K193526) to demonstrate substantial equivalence.
It's important to note that this document does not describe AI/ML device performance or studies proving such performance. This is a traditional medical device submission, focusing on compliance with established engineering and safety standards for the physical product.
Therefore, many of the requested elements pertaining to AI/ML device performance, such as sample size for test/training sets, data provenance, expert adjudication, MRMC studies, standalone algorithm performance, and ground truth establishment for AI models, are not applicable to this document.
The document primarily focuses on:
- Indications for Use: The device is for aspiration and injection of fluids, with a safety shield to prevent needle sticks.
- Technological Characteristics: Comparison of physical attributes like syringe volume, needle gauge, length, and material.
- Performance Standards: Compliance with international standards for syringes, needles, luer connectors, and sterilization.
- Biocompatibility: Leveraged from a previously cleared device (K163161) due to identical patient contact materials.
However, I can extract information related to the physical device's "acceptance criteria" and the "study that proves the device meets the acceptance criteria" in the context of this traditional medical device submission.
Here's the breakdown based on the provided text, focusing on the physical device performance and safety, not AI/ML:
Acceptance Criteria and Study for Sterile Syringe with Safety Needle (K211753)
The acceptance criteria for this device are primarily defined by compliance with recognized international and national standards for medical devices, particularly those related to syringes, needles, luer connectors, biocompatibility, and sterility. The studies proving the device meets these criteria are non-clinical bench tests.
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria Category | Specific Standard/Requirement | Device Performance (How compliance was demonstrated) |
---|---|---|
Syringe Performance | ISO 7886-1: 2017 | Tested and demonstrated conformance to the standard. |
Needle Performance | ISO 7864: 2016 | Tested and demonstrated conformance to the standard. |
ISO 9626:2016 | Tested and demonstrated conformance to the standard. | |
Luer Connector Performance | ISO 80369-7: 2016 | Tested and demonstrated conformance to the standard for small-bore connectors. |
ISO 80369-20: 2015 | Used for common test methods for small-bore connectors. | |
Sharps Injury Protection | ISO 23908: 2011 | Tested and demonstrated conformance (for sharps protection features for single-use hypodermic needles). |
Biocompatibility | ISO 10993 standards | Leveraged existing data from predicate device K163161 due to identical patient contact materials and manufacturing processes. Implies no cytotoxicity, no intracutaneous reactivity, no sensitization, no systemic toxicity, no hemolysis, no pyrogenicity. (Specific tests for K163161 not detailed in K211753) |
USP Bacterial Endotoxins Test | Bacterial endotoxin limit evaluated on proposed device. | |
USP Particulate Matter in Injections | Particulate testing evaluated on proposed device. | |
Sterility | ISO 11135:2014, Annex B | EO Sterilized with a SAL of 10^-6 validated via an overkill method. |
Packaging Integrity | ASTM F1886/1886M-16 | Visual inspection performed. |
ASTM F88/F88-15 | Seal strength tested. | |
ASTM F1929-15 | Dye penetration tested. | |
Shipping Performance | ASTM D4169-16 | Simulated transportation testing performed. |
Shelf-life | ASTM F1980-16 | Shelf life of 3 years validated using accelerated aging. |
EO Residuals | ISO 10993-7:2008 | EO ECH residue testing performed. |
Labeling | 21 CFR part 801 | Complies with regulations. |
2. Sample size used for the test set and the data provenance
- Sample Size: The document does not specify the exact sample sizes used for each individual non-clinical bench test. These are typically defined by the testing standards (e.g., ISO, ASTM).
- Data Provenance: The tests were conducted to demonstrate compliance with international standards (ISO, ASTM, USP). The manufacturing entity is Jiangxi Hongda Medical Equipment Group Ltd. in China. The testing would have been conducted by the manufacturer or a certified testing laboratory. The data is retrospective in the sense that the testing was completed prior to submission for clearance.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Not Applicable. This is a traditional medical device (syringe with safety needle), not an AI/ML device relying on expert consensus for ground truth. Compliance is determined by objective physical and chemical testing against established engineering and biological standards.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not Applicable. As above, this is a traditional medical device; "adjudication" in the context of clinical reads or expert consensus for AI models is not relevant here. Test results are compared directly against the quantitative and qualitative requirements of the referenced 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 document refers to a physical medical device (syringe), not an AI/ML diagnostic or assistive tool. MRMC studies are irrelevant for this type of submission.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not Applicable. There is no algorithm or software component described in this submission that would require standalone performance testing.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
- Bench Testing Standards and Specifications: The "ground truth" for this device is its adherence to the performance requirements stipulated in the referenced international and national standards (e.g., ISO 7886-1 for syringe performance, ISO 9626 for needle tubing, ISO 80369-7 for luer connectors, ISO 10993 for biocompatibility, etc.). These standards define the acceptable mechanical, physical, chemical, and biological properties of the device.
8. The sample size for the training set
- Not Applicable. This is a hardware medical device, not an AI/ML model that requires a training set.
9. How the ground truth for the training set was established
- Not Applicable. As above, there is no AI/ML training set.
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(197 days)
Sterile Syringe with Safety needle for Single Use, Sterile Syringe for Single Use, Sterile Safety Needle
Sterile Syringe with Safety needle for Single Use in the aspiration and injection of fluids for medical purpose. After withdrawal of the needle from the body, the attached needle safety mechanism can be manually activated to cover the needle immediately after use to minimize risk of accidental needlesticks.
Sterile Syringe for Single Use is a sterile luer lock syringe which is intended to be used with a hypodermic needle for the aspiration and injection of fluids for medical purpose.
Sterile Safety Needle for Single Use is intended to be used with a luer lock syringe for aspiration and injection of fluids for medical purpose. After withdrawal of the needle from the body, the attached needle safety mechanism can be manually activated to cover the needle immediately after use to minimize risk of accidental needlesticks.
Sterile Syringe with Safety needle for Single Use is intended for manual and single use only to aspirate and inject of fluids for medical purpose, which consists of syringe (piston, barrel, plunger) and hypodermic needle with a safety mechanism. The proposed device is available in a variety combination of syringe volume and needle size.
The Sterile Syringe for Single Use is intended for manual and single use only, which consists of piston, barrel and plunger. The proposed device is available in a variety syringe volume. The syringe is available in luer lock, which is intended to be connected with a hypodermic needle.
Sterile Safety Needle for Single Use is intended for manual and single use only to aspirate and inject of fluids for medical purpose, which consists of needle tube, retractable cartridge, jointing medium and needle hub. The proposed device is available in variety of needle gauge and needle length. According to the needle length, the safety mechanism is available in 2-part cartridge (outer retractable cartridge and inner retractable cartridge) and 3-part cartridge (outer retractable cartridge, middle retractable cartridge and inner retractable cartridge). The proposed device is compatible for use with a luer lock syringe. After withdrawal of the needle from the body, the attached needle safety mechanism can be manually activated to cover the needle immediately after use to minimize risk of accidental needlesticks.
The provided text describes a submission for K192679 (Sterile Syringe with Safety Needle for Single Use, Sterile Syringe for Single Use, Sterile Safety Needle for Single Use) to the FDA, asserting substantial equivalence to predicate device K170651.
The document discusses acceptance criteria for various tests and confirms that the proposed device met these criteria through non-clinical testing and a simulated clinical study.
Here's a breakdown of the requested information based on the provided text:
1. A table of acceptance criteria and the reported device performance
Test Category | Specific Test / Standard | Acceptance Criteria | Reported Device Performance |
---|---|---|---|
Physical, Mechanical, Chemical | Clause 5 of ISO 7886-1:2017 | General requirements | Conforms with requirements of related standards. |
Clause 6 of ISO 7886-1:2017 | Extraneous matter | Conforms with requirements of related standards. | |
Clause 7 of ISO 7886-1:2017 | Lubricant | Conforms with requirements of related standards. | |
Clause 8 of ISO 7886-1:2017 | Tolerance on graduated capacity (Syringe) | Met the requirements of ISO 7886-1. | |
Clause 9 of ISO 7886-1:2017 | Graduated scale | Conforms with requirements of related standards. | |
Clause 10 of ISO 7886-1:2017 | Barrel | Conforms with requirements of related standards. | |
Clause 11 of ISO 7886-1:2017 | Piston/plunger assembly | Conforms with requirements of related standards. | |
Clause 12 of ISO 7886-1:2017 | Nozzle | Conforms with requirements of related standards. | |
Clause 13 of ISO 7886-1:2017 | Performance (Syringe) | Met the requirements of ISO 7886-1. | |
Clause 4.3 of ISO 7864:2016 | Cleanliness (Needle) | Complies with ISO 7864. | |
Clause 4.4 of ISO 7864:2016 | Limits for acidity or alkalinity (Needle) | Complies with ISO 7864. | |
Clause 4.5 of ISO 7864:2016 | Limits for extractable metals (Needle) | Complies with ISO 7864. | |
Clause 4.6 of ISO 7864:2016 | Size designation (Needle) | Complies with ISO 7864. | |
Clause 4.7 of ISO 7864:2016 | Colour coding (Needle) | Complies with ISO 7864. | |
Clause 4.8 of ISO 7864:2016 | Needle hub | Complies with ISO 7864. | |
Clause 4.9 of ISO 7864:2016 | Needle Cap | Complies with ISO 7864. | |
Clause 4.10 of ISO 7864:2016 | Needle tube | Complies with ISO 7864. | |
Clause 4.11 of ISO 7864:2016 | Needle point | Complies with ISO 7864. | |
Clause 4.12 of ISO 7864:2016 | Bond between hub and needle tube | Complies with ISO 7864. | |
Clause 4.13 of ISO 7864:2016 | Patency of lumen | Complies with ISO 7864. | |
Clause 5.2 of ISO 9626:2016 | Surface finish and appearance | Complies with ISO 9626. | |
Clause 5.3 of ISO 9626:2016 | Cleanliness | Complies with ISO 9626. | |
Clause 5.4 of ISO 9626:2016 | Limits for acidity and alkalinity | Complies with ISO 9626. | |
Clause 5.5 of ISO 9626:2016 | Size designation | Complies with ISO 9626. | |
Clause 5.6 of ISO 9626:2016 | Dimensions | Complies with ISO 9626. | |
Clause 5.8 of ISO 9626:2016 | Stiffness | Complies with ISO 9626. | |
Clause 5.9 of ISO 9626:2016 | Resistance to breakage | Complies with ISO 9626. | |
Clause 5.10 of ISO 9626:2016 | Resistance to corrosion | Complies with ISO 9626. | |
Sterile Barrier Packaging | ASTM F1886/F1886M-16 | Visual inspection | Maintain its integrity. |
ASTM F88/F88-15 | Seal strength | Maintain its integrity. | |
ASTM F1929-15 | Dye penetration test | Maintain its integrity. | |
Sterilization and Shelf Life | ISO 10993-7:2008 | EO residue limit | Did not exceed the limit. |
ISO 10993-7:2008 | ECH residue limit | Did not exceed the limit. | |
USP 38-NF 33 | Bacteria Endotoxin Limit (20EU/device) | Did not exceed 20EU/device. | |
Physical, Mechanical, Chemical, Package Test on aging samples | Maintain its performance during the claimed shelf life. | Maintained its performance during the claimed shelf life. | |
Biocompatibility | ISO 10993-1 series (Tests for blood path, indirect, |
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(253 days)
Safety Needles, Sterile Syringe, Sterile Syringe with Safety Needle, Sterile Syringe with Needle, Hypodermic
Safety Needles: The safety needles are intended to be used with a luer slip or luer lock syringe for aspiration and injection of fluids for medical purpose. After withdrawal of the needle from the body, the attached needle safety shield can be manually activated to cover the needle immediately after use to minimize risk of accidental needlestick.
Sterile Syringe: The sterile syringe is a sterile luer slip syringe which is intended to be used with a hypodermic needle for the aspiration and injection of fluids for medical purpose.
Sterile Syringe with Safety Needle: The sterile syringe with safety needle is intended for use in the aspiration of fluids for medical purpose. After withdrawal of the needle from the body, the attached needle safety shield can be manually activated to cover the needle immediately after use to minimize risk of accidental needle sticks.
Sterile Syringe with Needle: The sterile syringe with needle is intended for use the aspiration of fluids for medical purpose.
Hypodermic Needles for Single Use: The hypodermic needle is intended to be used with a luer slip or luer lock syringe for aspiration of fluids for medical purpose.
(1)Safety Needles: The Safety Needles are intended for manual and single use only. They consist of a needle cap, needle tube and hub with protector. The proposed device is compatible for use with a luer slip or luer lock syringe. The safety sheath will be manually activated to cover the needle immediately after use to minimize risk of accidental needle sticks.
(2)Sterile Syringe: The Sterile Syringe is intended for manual and single use only. It consists of a Barrel, Plunger, and Piston. The syringes are available with luer slip and luer lock connector types and are available in different sizes. They are intended to be connected to a safety/hypodermic needle.
(3)Sterile Syringe with Safety Needle: This product is intended for manual and single use only. The Sterile Syringe with Safety Needle consists of a hypodermic needle with a safety sheath attached to the needle hub and a luer slip or luer lock syringe. The proposed device is available in a variety of syringe and needle sizes. The safety sheath will be manually activated to cover the needle immediately after use to minimize risk of accidental needle sticks.
(4)Sterile Syringe with Needle: The Sterile Syringe with Needle is intended for manual and single use only. It consists of a hypodermic needle and a luer slip or luer lock syringe. The proposed device is available in a variety of syringe and needle sizes.
(5)Hypodermic Needles for Single Use: The Hypodermic Needle is intended for manual and single use only. It consists of a hub, needle tube, needle cap. The proposed device is compatible for use with a luer slip or luer lock syringe.
The provided document is a 510(k) Premarket Notification from Jiangsu Micsafe Medical Technology Co., Ltd. for various sterile syringe and needle products. This type of submission aims to demonstrate that a new device is "substantially equivalent" to a legally marketed predicate device, rather than proving its "safety and effectiveness" through clinical trials as is typically done for novel devices.
Therefore, the document does not contain the kind of acceptance criteria, study details, and performance metrics typically associated with AI/ML-enabled medical devices that would involve a "test set," "ground truth," "expert adjudication," or "MRMC comparative effectiveness studies." The acceptance criteria and "study" described in this document relate to demonstrating substantial equivalence through non-clinical bench testing to established international standards for medical devices like needles and syringes, and biocompatibility.
Here's an analysis based on the information provided in the document, framed to address the prompt's categories where applicable, and noting where the information is not present or not relevant to the prompt's context (which often implies AI/ML or diagnostic performance studies):
Acceptance Criteria and Device Performance (based on provided document):
The document defines acceptance criteria by adhering to established ISO and ASTM standards for medical devices. The "performance" is the successful demonstration of conformity to these standards.
Acceptance Criteria (Standard & Requirement) | Reported Device Performance |
---|---|
Biocompatibility (per ISO 10993 series & ASTM F756-17): |
- No Cytotoxicity
- No Irritation to Skin
- No significant evidence of sensitization
- No systemic toxicity
- No Hemolysis
- Non pyrogenic | Conforms to the requirement of ISO 10993 series Standards:
- No Cytotoxicity
- No Irritation to Skin
- No significant evidence of sensitization
- No systemic toxicity
- No Hemolysis
- Non pyrogenic |
| Safety Needles Performance (per ISO 7864 & ISO 9626, and ISO 23908:2011 for safety feature): - Force to activate safety mode: NMT 10N
- Force to disengage safety mode: NLT 20N
- Force to separate safety feature from needle hub: NLT 50N | Conforms with the requirements of ISO 7864 and ISO 9626.
Needle Safety Feature: Testing conducted per ISO 23908:2011. - Force to activate safety mode: NMT 10N
- Force to disengage safety mode: NLT 20N
- Force to separate safety feature from needle hub: NLT 50N |
| Sterile Syringe Performance (per ISO 7886 & ISO 80369-7): - Cleanliness
- Limits for acidity or alkalinity
- Lubricant
- Tolerance on graduated capacity
- Scale, etc. | Conforms with the requirements of ISO 7886 and ISO 80369-7. (Specific values not provided in summary table, but implied by conformity statement) |
| Sterile Syringe with Safety Needle Performance (per ISO 7864, ISO 9626, ISO 7886, ISO 80369-7, and ISO 23908:2011 for safety feature): - Same as individual components. | Conforms with the requirements of ISO 7864, ISO 9626, ISO 7886, and ISO 80369-7.
Needle Safety Feature: Testing conducted per ISO 23908:2011. - Force to activate safety mode: NMT 10N
- Force to disengage safety mode: NLT 20N
- Force to separate safety feature from needle hub: NLT 50N |
| Sterile Syringe with Needle Performance (per ISO 7864, ISO 9626, ISO 7886, ISO 80369-7): - Same as individual components. | Conforms with the requirements of ISO 7864, ISO 9626, ISO 7886, and ISO 80369-7. (Specific values not provided in summary table, but implied by conformity statement) |
| Hypodermic Needles for Single Use (per ISO 7864 & ISO 9626): - Cleanliness
- Limits for acidity or alkalinity
- Limits for extractable metals
- Color coding
- Conical fitting, etc. | Conforms with the requirements of ISO 7864 and ISO 9626. (Specific values not provided in summary table, but implied by conformity statement) |
| Particulate Testing (per USP ): | Performed (Result of conformity implied by overall conclusion of substantial equivalence). |
Regarding the prompt's specific questions:
-
A table of acceptance criteria and the reported device performance:
- See table above. The "performance" is reported as conformance to the specified ISO/ASTM standards and the specific thresholds for the safety features.
-
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 exact sample sizes for each non-clinical bench test. The testing is described as complying with the requirements of the listed ISO/ASTM standards, which typically prescribe sample sizes for such tests.
- Data Provenance: The tests were conducted by the manufacturer, Jiangsu Micsafe Medical Technology Co., Ltd. (China). The data would be specific to their manufactured devices, and these are non-clinical, bench-top tests, not human subject data.
-
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 submission is for physical medical devices (needles, syringes), not AI/ML software or diagnostic devices that require expert review of ground truth in the context of images or clinical data. The "ground truth" for these devices is defined by the performance specifications of the international standards themselves (e.g., a needle must meet certain force requirements, be free from defects, etc.). The experts involved are likely engineers or quality control specialists who conduct and verify the bench tests.
-
Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- None. This concept is not relevant to non-clinical bench testing of physical medical devices. Adjudication methods are typically used in clinical studies, especially those involving subjective interpretations (e.g., by radiologists) to establish a consensus ground truth.
-
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. This type of study is specifically for evaluating the impact of AI/ML algorithms on human reader performance, typically in diagnostic imaging. It is not relevant to the evaluation of sterile syringes and needles.
-
If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. This concept pertains to the performance of an AI/ML algorithm by itself. The devices described (needles and syringes) are physical instruments for manual use, not software algorithms.
-
The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- Ground Truth: For these devices, "ground truth" is established by adherence to globally recognized technical standards (ISO 7864, ISO 9626, ISO 7886, ISO 80369-7, ISO 23908, ISO 10993 series, USP , ASTM F756-17). These standards specify the physical, chemical, and biological properties and performance requirements for the devices. The "ground truth" is objective measurement and verification against these specified parameters, not subjective expert consensus on complex clinical cases or pathology.
-
The sample size for the training set:
- Not applicable. This document describes the testing of a medical device, not the development or validation of an AI/ML model that would use training data.
-
How the ground truth for the training set was established:
- Not applicable. As there is no AI/ML model or "training set," this question is not relevant.
Summary with respect to the 510(k) submission's purpose:
The document focuses on demonstrating substantial equivalence to an existing predicate device (K170651) by showing that the new devices meet the same safety and performance standards through non-clinical bench testing and biocompatibility assessments. The differences between the subject device and the predicate device (e.g., differences in available sizes, slight variations in luer connections, and specific safety feature force values) were addressed by demonstrating compliance with the relevant international standards. The FDA's clearance (K183665) indicates that the agency agreed that this non-clinical data was sufficient to establish substantial equivalence for these types of medical devices.
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