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510(k) Data Aggregation

    K Number
    K192679
    Date Cleared
    2020-04-10

    (197 days)

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

    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.

    Device Description

    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.

    AI/ML Overview

    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 CategorySpecific Test / StandardAcceptance CriteriaReported Device Performance
    Physical, Mechanical, ChemicalClause 5 of ISO 7886-1:2017General requirementsConforms with requirements of related standards.
    Clause 6 of ISO 7886-1:2017Extraneous matterConforms with requirements of related standards.
    Clause 7 of ISO 7886-1:2017LubricantConforms with requirements of related standards.
    Clause 8 of ISO 7886-1:2017Tolerance on graduated capacity (Syringe)Met the requirements of ISO 7886-1.
    Clause 9 of ISO 7886-1:2017Graduated scaleConforms with requirements of related standards.
    Clause 10 of ISO 7886-1:2017BarrelConforms with requirements of related standards.
    Clause 11 of ISO 7886-1:2017Piston/plunger assemblyConforms with requirements of related standards.
    Clause 12 of ISO 7886-1:2017NozzleConforms with requirements of related standards.
    Clause 13 of ISO 7886-1:2017Performance (Syringe)Met the requirements of ISO 7886-1.
    Clause 4.3 of ISO 7864:2016Cleanliness (Needle)Complies with ISO 7864.
    Clause 4.4 of ISO 7864:2016Limits for acidity or alkalinity (Needle)Complies with ISO 7864.
    Clause 4.5 of ISO 7864:2016Limits for extractable metals (Needle)Complies with ISO 7864.
    Clause 4.6 of ISO 7864:2016Size designation (Needle)Complies with ISO 7864.
    Clause 4.7 of ISO 7864:2016Colour coding (Needle)Complies with ISO 7864.
    Clause 4.8 of ISO 7864:2016Needle hubComplies with ISO 7864.
    Clause 4.9 of ISO 7864:2016Needle CapComplies with ISO 7864.
    Clause 4.10 of ISO 7864:2016Needle tubeComplies with ISO 7864.
    Clause 4.11 of ISO 7864:2016Needle pointComplies with ISO 7864.
    Clause 4.12 of ISO 7864:2016Bond between hub and needle tubeComplies with ISO 7864.
    Clause 4.13 of ISO 7864:2016Patency of lumenComplies with ISO 7864.
    Clause 5.2 of ISO 9626:2016Surface finish and appearanceComplies with ISO 9626.
    Clause 5.3 of ISO 9626:2016CleanlinessComplies with ISO 9626.
    Clause 5.4 of ISO 9626:2016Limits for acidity and alkalinityComplies with ISO 9626.
    Clause 5.5 of ISO 9626:2016Size designationComplies with ISO 9626.
    Clause 5.6 of ISO 9626:2016DimensionsComplies with ISO 9626.
    Clause 5.8 of ISO 9626:2016StiffnessComplies with ISO 9626.
    Clause 5.9 of ISO 9626:2016Resistance to breakageComplies with ISO 9626.
    Clause 5.10 of ISO 9626:2016Resistance to corrosionComplies with ISO 9626.
    Sterile Barrier PackagingASTM F1886/F1886M-16Visual inspectionMaintain its integrity.
    ASTM F88/F88-15Seal strengthMaintain its integrity.
    ASTM F1929-15Dye penetration testMaintain its integrity.
    Sterilization and Shelf LifeISO 10993-7:2008EO residue limitDid not exceed the limit.
    ISO 10993-7:2008ECH residue limitDid not exceed the limit.
    USP 38-NF 33 <85>Bacteria Endotoxin Limit (20EU/device)Did not exceed 20EU/device.
    Physical, Mechanical, Chemical, Package Test on aging samplesMaintain its performance during the claimed shelf life.Maintained its performance during the claimed shelf life.
    BiocompatibilityISO 10993-1 series (Tests for blood path, indirect, <24 hours contact)No negative impacts from materials.No negative impacts reported for Cytotoxicity, Sensitization, Intracutaneous reactivity, Acute Systemic Toxicity, Hemolysis, Complement activation, Thromboresistance study, Pyrogen, Particulate testing.
    Safety FeatureFDA Guidance for Industry and FDA Staff: Medical Device with Sharps Injury Prevention Feature, issued on August 9, 2005 and ISO 23908:2011Meet pre-established criteria (Simulated Clinical Study).Meet acceptance criteria (Safety Feature Test performed on both proposed and predicate).Met the pre-established criteria. (Proposed device) Met the acceptance criteria. (Proposed device and predicate device)
    Connect Type (Luer lock)ISO 80369-7Performance of Luer lock.Met the requirements of ISO 80369-7.

    2. Sample sizes used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    The document does not explicitly state the numerical sample sizes for each test set. It mentions tests were performed on the "proposed device" and "aging samples" for shelf-life. In the Safety Feature Test, tests were performed on "both proposed device and predicate device".

    The data provenance is from non-clinical tests conducted by Gemtier Medical (Shanghai) Inc. in China (manufacturer location). The nature of these tests (bench testing, simulated clinical study) implies they are prospective in execution, meaning they were designed and performed for the purpose of this submission.

    3. 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)

    This section is not applicable as the document describes non-clinical and simulated clinical studies for a medical device (syringes and needles), not studies involving human subjects or expert assessment of medical images/data for ground truth. The acceptance criteria are based on compliance with international standards and internal design specifications, not expert consensus on medical conditions.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    This section is not applicable. Adjudication methods are typically used in clinical studies or studies where subjective interpretations need to be resolved. The tests described here are objective performance measurements against established 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

    This is not applicable. The device is a sterile syringe and needle system, not an AI-powered diagnostic or assistive technology that would involve human readers or AI assistance.

    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 medical instrument, not an algorithm.

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

    The "ground truth" for the device's performance is established by the international standards (e.g., ISO 7886-1, ISO 7864, ISO 9626, ISO 10993-7, ISO 23908, ISO 80369-7) and internal design specifications against which the device was tested. For biocompatibility, the lack of "negative impacts" is the ground truth. For the safety mechanism, meeting "pre-established criteria" of relevant guidance documents serves as the ground truth.

    8. The sample size for the training set

    This is not applicable. The document describes the testing and comparison of a physical medical device. There is no training set mentioned, as this is not an AI/ML device.

    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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