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510(k) Data Aggregation

    K Number
    K162180
    Date Cleared
    2016-12-29

    (147 days)

    Product Code
    Regulation Number
    880.5860
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The disposable insulin syringe is intended for medical purposes for the manual aspiration of U-100 insulin, and for the injection of insulin into parts of the body below the surface skin.

    Device Description

    The proposed device is a syringe with fixed needle tube which is intended for injection the manual aspiration of insulin, and for the injection of insulin into parts of the body below the surface skin. The insulin is injected to subcutaneous tissue by pushing force generated through pushing plunger rod of the insulin syringe. The proposed devices are provided sterile, single use.

    The proposed device is available in 0.3ml, 0.5ml and 1ml volumes.

    AI/ML Overview

    This document describes the premarket notification (510(k)) for the Disposable Insulin Syringe (K162180) by Berpu Medical Technology Co., Ltd. The submission aims to demonstrate substantial equivalence to a predicate device (K072739).

    Here's an analysis of the acceptance criteria and study information provided:

    1. Table of Acceptance Criteria and Reported Device Performance

    The device performance is demonstrated by compliance with various international standards for medical devices and specific tests. The table below summarizes these, acting as both acceptance criteria and reported performance (as the tests were performed to verify compliance).

    Acceptance Criteria (Standard & Clause)Reported Device Performance
    For materials (ISO 9626:1991/AMD-1:2001)
    Clause 3: MaterialsComplies
    Clause 4: Surface finishComplies
    Clause 5: CleanlinessComplies
    Clause 6: Limits for acidity and alkalinityComplies
    Clause 7: Size designationComplies
    Clause 8: DimensionsComplies
    Clause 9: StiffnessComplies
    Clause 10: Resistance to breakageComplies
    Clause 11: Resistance to corrosionComplies
    For sterility/cleanliness (ISO 7864:1993)
    Clause 4: CleanlinessComplies
    Clause 5: Limits for acidity or alkalinityComplies
    Clause 6: Limits for extractable metalsComplies
    Clause 7: Size designationComplies
    Clause 8: Colour codingComplies
    Clause 9: Needle hubComplies
    Clause 10: SheathComplies
    Clause 11: Needle tubeComplies
    Clause 12: Needle pointComplies
    Clause 13: PerformanceComplies
    For insulin syringes (ISO 8537:2007)
    Clause 5: Freedom from extraneous matterComplies
    Clause 6: Limits for extraneous matterComplies
    Clause 7: Lubrication of syringes and needlesComplies
    Clause 8: Range of sizeComplies
    Clause 9: Graduated scaleComplies
    Clause 10: BarrelComplies
    Clause 11: Piston/plunger assemblyComplies
    Clause 13: Needle tubing and needlesComplies
    Clause 14: Performance of assembled syringeComplies
    Clause 9.1: Dose Accuracy testingComplies
    Sterile Barrier Packaging Testing
    ASTM F88/F88-09: Seal strengthComplies
    ASTM F1140/F1140M-13: Internal pressureComplies
    ASTM F1929-12: Dye penetrationComplies
    Sterilization and Shelf Life Testing
    SAL: 10-6Achieved SAL 10-6
    Validation method: ISO 11135:2014Validation performed
    EO residue: ISO 10993-7:2008Complies with ISO 10993-7:2008
    ECH residue: ISO 10993-7:2008Complies with ISO 10993-7:2008
    Bacteria Endotoxin Limit: USP 38-NF 33 <85>Complies (No evidence of pyrogens)
    LAL Pyrogen Test: ISO 10993-11:2006Complies (No evidence of pyrogens)
    Shelf Life Evaluation (Physical, Mechanical, Chemical, Package, Sterility)Tests performed on accelerated aging samples to verify claimed shelf life
    Biocompatibility Testing (ISO 10993 standards)
    CytotoxicityNo cytotoxicity
    IrritationNo irritation reactivity
    SensitizationNo significant evidence of skin sensitization
    Systemic ToxicityNo significant evidence of systemic toxicity
    HemolysisNo evidence of hemolysis
    Pyrogen (mentioned again in comparison table)No evidence of pyrogens

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

    The document does not specify the exact sample sizes for each of the physical, mechanical, chemical, packaging, sterilization, or biocompatibility tests. It broadly states that "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 Berpu Medical Technology Co., Ltd in China, as they are the sponsor. The studies are prospective in the sense that they are conducted on the device being submitted for approval.

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

    This information is not provided. The ground truth for these types of device performance tests is typically established by compliance with international standards and validated testing methodologies, rather than expert consensus on individual cases.

    4. Adjudication method for the test set

    This information is not provided, as the studies are device performance tests against pre-defined standards, not typically involving adjudication of subjective outcomes by experts.

    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

    A MRMC comparative effectiveness study was not done. This device is a disposable insulin syringe, not an AI-powered diagnostic or assistive tool for human readers.

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

    This is not applicable to a disposable insulin syringe, which is a physical medical device and not an algorithm. Therefore, no standalone algorithm performance study was conducted.

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

    The ground truth for the performance of the Disposable Insulin Syringe is largely based on compliance with established international and national standards (ISO 9626, ISO 7864, ISO 8537, ISO 11135, ISO 10993-7, ISO 10993-11, USP 38-NF 33 <85>, ASTM F88/F88-09, ASTM F1140/F1140M-13, ASTM F1929-12). These standards define acceptable ranges, limits, and methodologies for evaluating the physical, mechanical, chemical, and sterility properties of such devices.

    8. The sample size for the training set

    This is not applicable. The device is a physical medical instrument, not an AI model, and therefore does not have a "training set" in the context of machine learning.

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

    This is not applicable, as there is no training set for this device.

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