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510(k) Data Aggregation

    K Number
    K153706
    Date Cleared
    2016-08-29

    (250 days)

    Product Code
    Regulation Number
    880.5570
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

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

    Device Description

    The proposed device, Pen Needle, is a single-use device, which is designed for use with a pen injector for the subcutaneous injection of insulin. It consists of needle tubing, needle tip shield, needle base, needle base shield, sealing dialysis paper, glue and silicone oil. The needle base can be connected screwed onto the insulin pen.

    The Pen Needle is offered in various gauge size and length.

    The proposed device is available in radiation sterilized to achieve a Sterility Assurance Level (SAL) of 10-6.

    AI/ML Overview

    This document describes the non-clinical testing performed to demonstrate the substantial equivalence of the "Easy Drip Disposable Insulin Needle" to a predicate device.

    Here's a breakdown of the requested information:

    1. Table of Acceptance Criteria and Reported Device Performance

    TestAcceptance CriteriaReported Device Performance
    MaterialThe needle shall be made of tubing materials specified in ISO 9626.Complied
    DimensionsThe needles shall fit the test apparatus specified in item 7.3 of ISO 11608-2.Complied
    Flow rate through the needleThe needles were tested in accordance with Annex A to ISO 11608-2.Complied
    Binding force between needle base and needle tubingThe union of the hub and needle tube shall not break when tested in accordance with Clause 9 of ISO 11608-2.Complied
    Needle tip appearance, needle tubing flawlessness, size of inside and outside diameter and puncturing forceThe needle tip appearance shall fulfil the 4.5 of ISO 11608-2. The needle tubing flawlessness shall fulfil the requirements of ISO 7864:1993, 11.3.Complied
    Dislocation of measuring point patient endDislocation of the cannula point at the patient end shall be in accordance with Table 2 (ISO 11688-2) when tested in accordance with Clause 8 of ISO 11608-2.Complied
    Functional compatibility with needle-based injected systemsCompatibility with any NIS shall be claimed only after testing in accordance with Clause 11 of ISO 11608-2.Complied
    Ease of assembly and disassemblyAttachment of the needle shall be possible without removing the needle from its opened unit packaging. Compliance is checked according to the requirements of Clause 11 of ISO 11608-2.Complied
    Biocompatibility - CytotoxicityISO 10093-5 Biological evaluation of medical devices - Part 5: Tests for in vitro cytotoxicityUnder the conditions of the study, the subject device showed no evidence of cytotoxicity.
    Biocompatibility - SensitizationISO 10993-10 Biological evaluation of medical devices - Part 10: Tests for irritation and skin sensitizationUnder the conditions of the study, the subject device showed no evidence of sensitization.
    Biocompatibility - IrritationISO 10993-10 Biological evaluation of medical devices - Part 10: Tests for irritation and skin sensitizationUnder the conditions of the study, the subject device showed no evidence of skin irritation.
    Biocompatibility - HemocompatibilityISO 10993-4 Biological evaluation of medical devices Part 4: Selection of tests for interactions with blood ASTM F765 Standard Practice for Assessment of Hemolytic Properties of MaterialsUnder the conditions of the study, the subject device showed no evidence of hemolysis.
    Biocompatibility - Systemic toxicity (acute)ISO 10993-11:2006/(R)2010, Biological evaluation of medical devices - Part 11: Tests for systemic toxicity.Under the conditions of the study, the subject device showed no evidence of systemic toxicity.
    Biocompatibility - PyrogenUSP 34 NF 29 <151> Pyrogen Test & USP <85>.non-pyrogenic
    Sterility Assurance Level (SAL)Achieve a SAL of 10^-6The validation report demonstrates that the sterilization of the proposed device can achieve a Sterility Assurance Level (SAL) of 10^-6. The radiation dose audit test reports showed that the minimum gamma radiation dose to achieve a 10^-6 SAL was acceptable according to ISO 11737-2:2012. (Note: The document states 10^8 in one place but implies 10^-6 is met).

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

    The document does not specify the exact sample sizes used for each non-clinical test. However, it indicates that "nonclinical tests were conducted to verify that the proposed device met all design specifications" and that the "test results demonstrated that the proposed device complies with the following standards." The provenance of the data is not explicitly stated in terms of country of origin, nor is it classified as retrospective or prospective; these are laboratory bench tests.

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

    Not applicable. These were non-clinical bench tests performed against established international standards (ISO, ASTM, USP). Expert consensus is not typically used to establish ground truth for these types of tests; rather, the ground truth is defined by the objective pass/fail criteria of the specified standards.

    4. Adjudication method for the test set

    Not applicable. As noted above, these were objective non-clinical bench tests against standardized criteria.

    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 pertains to a medical device (insulin needle) and its non-clinical performance and biocompatibility, not an AI-assisted diagnostic tool.

    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.

    7. The type of ground truth used

    The ground truth for the non-clinical tests was established by adherence to and compliance with relevant international and national standards, including:

    • ISO 7864 (Sterile hypodermic needles for single use)
    • ISO 9626 (Stainless steel needle tubing for the manufacture of medical devices)
    • ISO 11608-2 (Pen-injectors for medical use - Part 2: Needles - Requirements and test methods)
    • ISO 10993 series (Biological evaluation of medical devices, including parts 4, 5, 10, 11)
    • ASTM F765 (Standard Practice for Assessment of Hemolytic Properties of Materials)
    • USP <151> Pyrogen Test
    • USP <85> Bacterial Endotoxins Test

    8. The sample size for the training set

    Not applicable. This is a physical medical device submission, not a machine learning model, so there is no "training set."

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

    Not applicable, for the same reason as above.

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