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510(k) Data Aggregation

    K Number
    K211293
    Date Cleared
    2021-06-25

    (60 days)

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

    The safety winged blood collection set is single-use, sterile, winged venipuncture needle bonded to a flexible tubing with or without a luer adaper and/or tube holder. The device is used for blood collection and/or the short-term infusion of intravenous fluids (up to 2 hours under direct clinical supervision). The blood-collection needle is designed to be covered with a safety mechanism, which can be activated to cover the needle immediately following venipuncture to aid in the protection against accidental needlestick injury.

    Device Description

    The Promisemed Safety Blood Collection sets are single-use, sterile, venipuncture needles used for blood collection or short-term infusion of intravenous fluids (up to 2 hours under direct clinical supervision). The blood-collection needle is designed to be covered with a safety mechanism, which can be activated to cover the needle immediately following venipuncture to aid in the protection against accidental needlestick injury.

    AI/ML Overview

    This document describes the premarket notification (510(k)) for the Promisemed Safety Winged Blood Collection Set. The core of this submission is to demonstrate "substantial equivalence" to a legally marketed predicate device (K170276). It does not involve AI or algorithms, but rather a physical medical device. Therefore, many of the requested elements regarding AI/algorithm performance are not applicable.

    Here's an analysis based on the provided document:

    1. A table of acceptance criteria and the reported device performance

    The acceptance criteria are demonstrated through adherence to various international and national standards, showing the device's conformance to established safety and performance benchmarks. The reported device performance is indicated by "passing results" for all tests.

    Acceptance Criteria (Standard / Test)Reported Device Performance
    Physical Performance
    Needle appearance and cleanliness (ISO 7864:2016, clause 4.3)Meets requirements
    Needle Size color code (ISO 6009:2016)Meets requirements
    Needle Particulate contamination (USP <788>, METHOD 1, Test 1.B)Meets requirements
    Bonding strength: Needle and hub (ISO 7864:2016, clause 4.12)Meets requirements
    Bonding strength: Tubing and hub (ISO 8536-4:2019, clause 7.3)Meets requirements
    Bonding strength: Tubing and double wings luer adapter (ISO 8536-4:2019, clause 7.3)Meets requirements
    Infusion set leakage (ISO 8536-4:2019, clause 7.2)Meets requirements
    Needle patency of lumen (ISO 7864:2016, clause 4.13, a)Meets requirements
    Dimension: Blood collection needle (ISO 9626:2016, clause 5.6, table 1, (TW))Meets requirements
    Dimension: Puncturing needle (ISO 9626:2016, clause 4.10.2, table1)Meets requirements
    Needle point (ISO 7864:2016, clause 4.11)Meets requirements
    Needle Lubrication: Appearance (ISO 7864:2016, clause 4.10.4)Meets requirements
    Needle Lubrication: Quantity (ISO 7886-1:2017, Annex F)Meets requirements
    Luer Connector (ISO 80369-7:2016, ISO 80369-20:2015)Meets requirements
    Tubing kink stability (ISO 20696:2018, clause 6.7)Meets requirements
    Puncture force of needle (ISO 7864:2016, clause 4.11)Meets requirements
    Safety protection mechanism (ISO 23908:2011)Meets requirements
    Stiffness of needle (ISO 9626:2016, clause 5.8, table 2 (TW))Meets requirements
    Toughness of needle (ISO 9626:2016, clause 5.9)Meets requirements
    Resistance to corrosion of needle (ISO 9626:2016, clause 5.10)Meets requirements
    Chemical Performance
    Reducing matter (ISO 8536-4:2019, clause 8.1)Meets requirements
    Metal ions (ISO 8536-4:2019, clause 8.2)Meets requirements
    Limits for acidity or alkalinity (ISO 8536-4:2019, clause 8.3)Meets requirements
    Residue on evaporation (ISO 8536-4:2019, clause 8.4)Meets requirements
    Ethylene oxide residue (EO&ECH) (ISO 10993-7:2008, clause 4.3.4)Meets requirements
    Biological Performance (Biocompatibility)
    Bacterial endotoxin (USP <85>)Passing results
    Sterility (USP <71>)Passing results
    Pyrogen Test (Rabbit) (USP <151>)Passing results
    Hemolytic Properties (ASTM F756-17)Passing results
    Hematology (ISO 10993-4:2017)Passing results
    Platelet CountPassing results
    Partial Thromboplastin TimePassing results
    Cytotoxicity (ISO 10993-5:2009)Passing results
    Skin Sensitization (ISO 10993-10:2010)Passing results
    Intracutaneous ReactivityPassing results
    Acute Systemic Toxicity (ISO 10993-11:2017)Passing results
    Safety Mechanism Activation (Sharps Injury Protection)
    Safety mechanism activation requirements (ISO 23908, internal protocol and test results)Meets requirements
    Safety overriding/unlocking force after activation requirements (ISO 23908, internal protocol and test results)Meets requirements
    Sterilization
    Sterility Assurance Level (SAL) of 10-6 (ISO 11135:2014 for Ethylene Oxide)Validated

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

    The document does not specify exact sample sizes for each test listed, but it indicates "Non-Clinical bench testing" was performed. The data provenance is implied to be from the manufacturer's internal testing in China (Promisemed Hangzhou Meditech Co., Ltd., Hangzhou City, Zhejiang, China). The tests are retrospective, as they are part of the device development and verification process before submission.

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

    Not applicable. This is a physical medical device. Ground truth is established through adherence to international standards and validated laboratory testing procedures for physical, chemical, and biological properties, not through expert consensus on images or interpretations.

    4. Adjudication method for the test set

    Not applicable. Adjudication methods like 2+1 or 3+1 are typically used in studies involving human interpretation (e.g., radiologists reading images) where disagreement might occur. For physical device testing, the results are typically quantitative or pass/fail based on 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

    Not applicable. This product is a physical blood collection device, not an AI or imaging diagnostic tool. Therefore, MRMC studies and human reader improvement are irrelevant.

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

    Not applicable. This product is a physical blood collection device, not an algorithm.

    7. The type of ground truth used

    The "ground truth" for this device's performance is established by the specified international and national consensus standards (e.g., ISO, USP, ASTM) for medical devices, which define acceptable physical, chemical, and biological properties. This includes:

    • Physical performance metrics: Bond strength, needle dimensions, patency, kink stability, puncture force, safety mechanism activation.
    • Chemical properties: Absence of harmful residues or leaching.
    • Biological properties: Biocompatibility tests (cytotoxicity, sensitization, irritation, systemic toxicity, hemolysis, pyrogenicity, bacterial endotoxin) and sterility.
    • Outcomes: The device is designed to prevent needlestick injuries, and its safety mechanism is tested to meet this outcome requirement.

    8. The sample size for the training set

    Not applicable. This is a physical medical device, not an AI/machine learning model. There is no "training set" in the context of this 510(k) submission.

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

    Not applicable. As there is no training set, this question is not relevant.

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