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510(k) Data Aggregation
(608 days)
The Sterile Syringe for Single Use (with Needle) is intended to be used for medical purposes to inject fluid into or withdraw fluid from body.
The Sterile Hypodermic Needle for Single Use is intended for use with syringes and injection devices for general purpose fluid injection/aspiration.
The Sterile Hypodermic Syringe is a sterile, single-use, polypropylene syringe that consists of the barrel, plunger, and stopper and is assembled with a hypodermic needle.
The Sterile Hypodermic Needle is a single lumen needle made of austenitic steel, consisting of a protective cap, a needle seat and a needle tube connection.
This document describes the FDA 510(k) premarket notification for a Sterile Syringe for Single Use (with Needle) and a Sterile Hypodermic Needle for Single Use by Jiangsu Zhiyu Medical Instrument Co., Ltd. The submission aims to demonstrate substantial equivalence to a legally marketed predicate device (K201284).
However, the provided text does not contain details about a study conducted to prove the device meets acceptance criteria in the context of an AI/human reader performance study. The document is a regulatory submission for a physical medical device (syringes and needles) and focuses on demonstrating substantial equivalence through bench testing (per ISO standards) and biocompatibility testing.
Therefore, I cannot provide the information requested in your prompt regarding:
- A table of acceptance criteria and reported device performance related to AI/human reader studies. The acceptance criteria discussed pertain to physical properties and safety of the syringe/needle, not diagnostic performance.
- Sample size and data provenance for an AI test set.
- Number of experts and qualifications for ground truth establishment for an AI study.
- Adjudication method for an AI test set.
- MRMC comparative effectiveness study results (AI vs. without AI assistance).
- Standalone (algorithm only) performance.
- Type of ground truth used (expert consensus, pathology, outcomes data) for an AI study.
- Sample size for the training set (for an AI model).
- How ground truth for the training set was established (for an AI model).
The document explicitly states: "No clinical study is included in this submission." This further confirms that no studies involving human reader performance comparisons or algorithm-only performance for diagnostic purposes (the typical context for MRMC or standalone AI studies) were conducted or submitted.
What the document DOES provide regarding acceptance criteria and performance:
The acceptance criteria for these devices are based on adherence to recognized international and US standards for medical devices, primarily ISO standards and USP. The "study" proving the device meets these criteria refers to bench testing, biocompatibility testing, and sterilization validation.
Here's a summary of the actual acceptance criteria and performance demonstrated (not a diagnostic AI study):
1. Table of Acceptance Criteria and Reported Device Performance (as per the document):
Acceptance Criteria Category | Specific Standard/Requirement | Reported Device Performance/Compliance |
---|---|---|
Material Properties | ISO 9626:2016 (Stainless steel needle tubing) | Complied with. (Ensures the physical integrity and performance of the needle tubing) |
Syringe Performance | ISO 7886-1:2017 (Sterile hypodermic syringes for single use) | Complied with. (Covers various aspects of syringe performance like accuracy of dose, resistance to leakage, plunger movement, barrel integrity. Explicitly stated: "The requirements of the standard are met" for the 2ml syringe volume difference.) |
Needle Performance | ISO 7864:2016 (Sterile hypodermic needles for single use) | Complied with. (Covers aspects like needle rigidity, resistance to breakage, patency, cannula-hub attachment strength. Explicitly stated: "The needles meet the requirements of the ISO 9626 and ISO 7864 standards" for needle length differences.) |
Biocompatibility | ISO 10993-4:2017 (Interactions with Blood) | Complied with. (Hemocompatibility tests conducted for patient-contact components). |
ISO 10993-5:2009 (In Vitro Cytotoxicity) | Complied with. (Cytotoxicity tests conducted for patient-contact components). | |
ISO 10993-10:2010 (Irritation and Skin Sensitization) | Complied with. (Irritation and sensitization tests conducted for patient-contact components). | |
ISO 10993-11:2017 (Systemic Toxicity) | Complied with. (Acute systemic toxicity tests conducted for patient-contact components). | |
Sterilization | ISO 10993-7:2008 (Ethylene oxide sterilization residuals) | Complied with. |
ISO 11135:2014 (Ethylene oxide sterilization validation) | Complied with. (Requirements for development, validation, and routine control of sterilization process). | |
Sterility Assurance Level | SAL | 10^-6 (This is a target SAL, indicating less than 1 in 1 million chance of a non-sterile unit after sterilization). The document implies this is achieved through validated processes per ISO 11135. |
Endotoxin Limit | Specified Limit | 20 EU per device. (Implied compliance, as this is listed as a characteristic similar to the predicate device). Pyrogen test (USP 43-NF38 ) was carried out. |
Particulate Matter | USP 788 (Particulate Matter in Injections) | Complied with. (Microscopic particle count test (USP 43-NF38 ) was carried out). |
Packaging | ISO 11607-2:2019 (Validation of packaging for terminally sterilized medical devices) | Complied with. |
2. Sample size used for the test set and data provenance:
- For physical and performance testing, the sample sizes would be based on the specific ISO standards and industry best practices for device testing, typically involving a statistically significant number of units to ensure consistency and reliability. The exact numbers are not provided in this summary document.
- Data provenance: This is a submission from Jiangsu Zhiyu Medical Instrument Co., Ltd. in China. The tests are internal company tests conducted to demonstrate compliance with standards.
3. Number of experts used to establish the ground truth and their qualifications:
- Not applicable in the context of this document. Ground truth for this type of device is established by adherence to engineering specifications and performance standards through laboratory testing, not expert clinical interpretation of images or patient data.
4. Adjudication method for the test set:
- Not applicable. Adjudication is relevant for subjective assessments, typically in clinical readings or AI ground truth labeling. Bench testing results are objective measurements against defined criteria.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done:
- No. The document explicitly states: "No clinical study is included in this submission."
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- No. This is not an AI device.
7. The type of ground truth used:
- The "ground truth" for this device's performance is defined by the specifications and acceptable limits set forth in the referenced ISO and USP standards. This includes, for example, specific force required to move a plunger, volume accuracy, needle sharpness, and biocompatibility limits. It is established through physical measurements and laboratory assays.
8. The sample size for the training set:
- Not applicable. This device does not use a training set as it is not an AI/ML device.
9. How the ground truth for the training set was established:
- Not applicable.
In summary, the provided document is for a conventional medical device (syringes and needles) seeking 510(k) clearance based on substantial equivalence to a predicate device, demonstrated through rigorous bench testing and adherence to recognized performance and safety standards, not through AI performance studies.
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(263 days)
The Sterile Syringe for Single Use is intended for use by health care professionals for general purpose aspiration and injection of fluids.
The Syringe with needle is intended for manual and single use only. It consists of six components 1) Barrel (luer lock or luer slip) 2) Plunger 3) Piston 4) Needle Tube 5) Protective Cap and 6) Needle Hub. The proposed device is available in various combination of syringe volume, connector type (luer lock or luer slip), connector location (central type or eccentric type) and needle size. The Syringe without needle is intended for manual and single use only. It consists of three components 1) Barrel (luer lock or luer slip) 2) Plunger and 3) Piston. The proposed syringe is available in various combination of syringe volume, connector type (luer lock or luer slip), and connector location (central type or eccentric type). The proposed device is sterilized by Ethylene Oxide to achieve a SAL of 106 and supplied in sterility maintenance package which could maintain the sterility of the device during the shelf life of 5 years.
The provided document is a 510(k) Summary for a Sterile Syringe for Single Use. It focuses on demonstrating substantial equivalence to a predicate device rather than detailing an AI/ML powered device. Therefore, many of the requested categories related to AI/ML device studies (such as MRMC studies, training set details, or ground truth establishment for AI models) are not applicable.
However, based on the information provided, here's a breakdown of the acceptance criteria and the study that proves the device meets those criteria, interpreted within the context of a medical device clearance:
1. A table of acceptance criteria and the reported device performance
The document defines "acceptance criteria" through compliance with recognized standards and the demonstration of substantial equivalence to a predicate device. The performance is reported as meeting these standards.
Acceptance Criteria Category | Specific Acceptance Criteria (Standard Reference or Characteristic) | Reported Device Performance (Compliance) |
---|---|---|
Biocompatibility | ISO 10993-5 (in Vitro Cytotoxicity) | No cytotoxicity |
ISO 10993-10 (Irritation and skin sensitization) | No intracutaneous reactivity, No skin sensitization | |
ISO 10993-11 (Systemic toxicity) | No systemic toxicity | |
ISO 10993-4 & ASTM F756-17 (Interaction with Blood, Hemolytic Properties) | No Hemolysis | |
Pyrogenicity Test | No Pyrogen (Implied acceptance criterion for sterile devices) | |
Material Safety | Endotoxin Limit | 20 EU per device |
Sterilization | Sterilization Method | EO Sterilization (Ethylene Oxide) |
Sterility Assurance Level (SAL) | 10-6 | |
Packaging Integrity | ASTM F88/F88M-15 (Seal Strength) | Complies |
ASTM F1929-15 (Seal Leaks by Dye Penetration) | Complies | |
Particulate Matter | USP (Particulate Matter for Injections, Method 1) | Complies |
Syringe Performance | ISO 7886-1:2017 (Sterile hypodermic syringes for single use - Part 1: Syringes for manual use) | Complies with ISO 7886-1 |
Needle Performance | ISO 7864:2016 (Sterile hypodermic needles for single use - Requirements and test methods) | Complies with ISO 7864 |
ISO 9626:2016 (Stainless Steel Needle Tubing) | Complies with ISO 9626 | |
ISO 6009:2016 (Hypodermic needles for single use - Colour coding) | Complies with ISO 6009 | |
Connector Compatibility | ISO 80369-7:2016 (Small-bore connectors for intravascular or hypodermic applications) | Complies with ISO 80369-7 |
ISO 80369-20:2015 (Common test methods for small-bore connectors) | Complies with ISO 80369-20 | |
General Requirements | Operation Mode | For manual use only (Same as predicate) |
Single Use | Single Use (Same as predicate) | |
Label/Labeling | Complies with 21 CFR part 801 (Same as predicate) |
2. Sample size used for the test set and the data provenance
The document does not specify exact sample sizes for each non-clinical test conducted. It states "Non-clinical tests were conducted to verify that the proposed device met all design specifications." The data provenance is implied to be from internal testing conducted by Jiangsu Suyun Medical Material Co., Ltd. or its contracted labs, with the country of origin being China (where the manufacturer is located). The testing is prospective for the purpose of this submission, meaning the tests were performed on the proposed device to gather data for regulatory submission.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This question is not applicable. The "ground truth" for a medical device like a sterile syringe is based on established engineering and biological standards (e.g., ISO, ASTM, USP) and laboratory measurements, not subjective expert assessment in the way it would be for an AI diagnostic tool. The "experts" involved are the certified laboratory technicians and quality control personnel who perform and interpret these standardized tests. Their qualifications are inherent in their ability to conduct these specific tests according to recognized protocols.
4. Adjudication method for the test set
This is not applicable in the context of this device and type of testing. The tests are typically objective measurements against defined pass/fail criteria in the standards. There is no mention of a human adjudication process for resolving conflicting results, as would be common in image interpretation studies.
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 is not applicable. The device is a physical sterile syringe, not an AI/ML-powered diagnostic or assistive tool.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done
This is not applicable. The device is a physical sterile syringe, not an algorithm.
7. The type of ground truth used
The "ground truth" for this device's performance relies on objective measurements from standardized non-clinical tests. These include:
- Biological/Chemical endpoint measurements: e.g., cell viability (cytotoxicity), skin reactions (irritation/sensitization), blood cell lysis (hemolysis), particulate counts, endotoxin levels.
- Physical performance measurements: e.g., seal strength, leak detection, plunger force, barrel integrity, needle sharpness and elasticity.
- Sterility verification: Growth/no-growth tests for sterility assurance.
The "ground truth" is defined by the Pass/Fail criteria specified within the referenced ISO, ASTM, and USP standards.
8. The sample size for the training set
This is not applicable. There is no AI/ML component or "training set" for this sterile syringe device. The document describes non-clinical performance testing.
9. How the ground truth for the training set was established
This is not applicable. As there is no AI/ML component, there is no training set and no ground truth established for one.
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