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510(k) Data Aggregation

    K Number
    K231856
    Manufacturer
    Date Cleared
    2024-03-15

    (266 days)

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

    TopFine**®** LDS (Low Dead Space) Syringe (2 models (TS-LDS2334, TS-LDS2534))

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

    TopFine® LDS (Low Dead Space) Syringe is intended for use to inject fluid into or withdraw fluids from the parts of body below the surface of the skin.

    Device Description

    The TopFine® LDS (Low Dead Space) Syringe is a device intended for medical purposes that consists of a calibrated hollow barrel and a movable plunger. At one end of the barrel there is a hypodermic single lumen needle which is a permanently attached. The device is used to inject fluids into, or withdraw fluids from, the body. It is made of plastic and silicone materials that allows for smooth plunger movement, and is manually operated. This is a single-use device. This product is packed by sterile paper and sterilized by Ethylene Oxide gas.

    The proposed device has 2 models depending on the diameter of the needle.

    AI/ML Overview

    The provided document is a 510(k) premarket notification for a medical device, specifically a syringe. It does not contain information about an Artificial Intelligence/Machine Learning (AI/ML) device. Therefore, it is not possible to describe acceptance criteria or a study related to AI/ML device performance.

    The document focuses on demonstrating substantial equivalence of the "TopFine® LDS (Low Dead Space) Syringe" to a predicate syringe through various performance tests and material comparisons.

    Here's an analysis based on the information provided, specifically addressing the technical performance of the syringe, not AI/ML:

    Acceptance Criteria and Reported Device Performance (Non-AI/ML Syringe)

    The document details various performance criteria for the syringe. There isn't a single table explicitly labeled "Acceptance Criteria and Reported Device Performance" with detailed numerical results for each criterion. However, the "Comparison of technological characteristics with the predicate device" section (page 5) and "Performance data" section (page 7) implicitly define the acceptance criteria by stating compliance with recognized standards and providing general results.

    Here's an attempt to construct a table based on the provided information, focusing on criteria where reported performance is available, even if only generally stated as "Same" or "Complies."

    Acceptance Criteria CategorySpecific Criteria / StandardAcceptance Criteria (Expected/Reference)Reported Device Performance (TopFine® LDS Syringe)
    General CharacteristicsRegulation Number21 CFR 880.5860Same (21 CFR 880.5860)
    Product CodeQNQSame (QNQ)
    Indications for UseIntended for use to inject fluid into or withdraw fluids from the parts of body below the surface of the skin.Same
    Type of usePrescription UseSame
    Mechanism of actionPlunger can be pulled and pushed along inside the barrel, allowing the syringe to take in and expel fluids through the connector to the patient.Same
    Number of usesSingle Use OnlySame
    Material (Needle)SUS 304Same (SUS 304)
    Material (Cap)PolypropyleneSame (Polypropylene)
    Material (Barrel)PolypropyleneSame (Polypropylene)
    Material (Plunger)PolypropyleneSame (Polypropylene)
    Material (Gasket)PolyisopreneSame (Polyisoprene)
    Needle Gauge23G, 25GSame (23G, 25G)
    Needle OD (23G)0.600 ~ 0.673 mmSame (0.600 ~ 0.673 mm)
    Needle OD (25G)0.500 ~ 0.530 mmSame (0.500 ~ 0.530 mm)
    Syringe nozzle typePermanently attachedSame
    Syringe capacity1 mlSame (1 ml)
    Performance - BiocompatibilityISO 10993-1 ClassificationExternally Communicating Device, Blood Path Indirect, Limited Contact ( acceptance criteriaMet USP acceptance criteria.
    Performance - PhysicalNeedle Length (23G, 25G)Predicate: 25.0 mm, 25.4 mm, 38.1 mmProposed: 26.5 mm (+1.5 / -2.5 mm) - Different, but performance verified.
    Hub/needle bond strength (23G)≥ 34 N (ISO 7864)Same (≥ 34 N)
    Hub/needle bond strength (25G)≥ 22 N (ISO 7864)Same (≥ 22 N)
    Dead space≤ 0.03 mlSame (≤ 0.03 ml)
    Performance Needle StandardISO 7864:2016Same (ISO 7864:2016)
    Needle Tubing StandardISO 9626:2016Same (ISO 9626:2016)
    Syringe StandardISO 7886-1:2017Same (ISO 7886-1:2017)
    Performance - SterilitySterilization MethodEO Gas, SAL=10-6Same (EO Gas, SAL=10-6)
    EO ResidueNot detected (LOD: 0.001)EO not detected.
    ECH ResidueNot detected (LOD: 0.02)ECH not detected.
    Pyrogen TestBacterial endotoxin USP , USPTesting conducted and met criteria.
    Package Integrity (ASTM D4169-22)Acceptable for protection and sterility maintenance after environmental conditioning and simulated transportation.All packaging is acceptable.
    Seal Peel TestComplies with ASTM F88/F88 -15Performed.
    Dye MigrationComplies with ASTM F1929-15Performed.
    Shelf Life3 years (validated using ASTM F1980-21)3 years validated.
    LabelingComplianceComplies with 21 CFR part 801Same (Complies with 21 CFR part 801)

    Since this is concerning a non-AI/ML medical device, the following points are not applicable or cannot be answered from the provided text:

    1. 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 specify exact sample sizes for each physical or biological test. It only mentions that tests were "conducted."
      • Data provenance (country of origin, retrospective/prospective) is not mentioned for the testing data.
    2. 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 as this is not an AI/ML device requiring expert ground truth for image/data interpretation. This refers to standard performance testing.
    3. Adjudication method (e.g. 2+1, 3+1, none) for the test set

      • Not applicable. Adjudication methods are typically for clinical studies involving human interpretation or AI/ML output.
    4. 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 not an AI/ML device. "Clinical studies were not required to support substantial equivalence."
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

      • Not applicable. This is not an AI/ML device.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

      • For the syringe, "ground truth" would be established by direct physical measurements, chemical analyses, and biological assays according to the specified international and national standards (e.g., ISO, USP, ASTM). For example, the "dead space" measurement itself would be the ground truth for that specific characteristic, and the acceptance criterion is a predefined maximum value (≤ 0.03 ml).
    7. The sample size for the training set

      • Not applicable. This is not an AI/ML device with a training set.
    8. How the ground truth for the training set was established

      • Not applicable. This is not an AI/ML device.

    In summary, the document addresses a traditional medical device (syringe) and demonstrates its substantial equivalence to a predicate device through adherence to manufacturing standards, material comparisons, and performance testing against established physical, chemical, and biological criteria, rather than through AI/ML performance metrics.

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