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510(k) Data Aggregation

    K Number
    K221777
    Date Cleared
    2023-10-06

    (472 days)

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

    Disposable Sterile Syringe is intended to inject fluids into or withdraw fluids from the body.

    Device Description

    Disposable Sterile Syringe, is a plastic syringe designed for intended to inject fluids into or withdraw fluids from the body. The product is a single use, sterile, non-toxic, non-pyrogenic, disposable syringe that consists of a barrel, plunger, Piston, Needle tube, Needle hub and Needle cap.

    All specifications of product subject to the same design and the difference between each specification is syringe volume and needle size. The product is available in a variety combination of needle size and syringe volume.

    AI/ML Overview

    The provided text describes the 510(k) summary for a Disposable Sterile Syringe (K221777) and its substantial equivalence to a predicate device. This document is a regulatory submission for a medical device that does not involve AI or complex software, and therefore, many of the requested details regarding acceptance criteria, study methodologies for AI/software performance (e.g., sample size for test sets, expert adjudication, MRMC studies, standalone performance, ground truth for AI), and training set information are not applicable.

    The device is a simple, physical product (a syringe) and its "performance" is assessed through adherence to established international and ASTM standards for physical, chemical, and biological properties, as well as sterility and packaging integrity. The acceptance criteria for such a device are primarily defined by these international standards.

    Here's an attempt to address the points based on the provided document, highlighting what is applicable and what isn't:


    Device: Disposable Sterile Syringe (K221777)
    Purpose: Intended to inject fluids into or withdraw fluids from the body.

    This device is a traditional medical device, not an AI/Software as a Medical Device (SaMD). Therefore, the concept of "acceptance criteria" and "study that proves the device meets the acceptance criteria" refers to compliance with recognized standards and biocompatibility testing, rather than performance metrics like sensitivity, specificity, or AUC for an AI algorithm.


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

    The acceptance criteria for this device are its compliance with various ISO and ASTM standards. The "reported device performance" is essentially that the device "meets the requirements of related standards" and that "there are no negative impacts from the materials that are used in the proposed device."

    Item / Test CategoryStandard / Acceptance Criteria (Derived from document)Reported Device Performance (Summary from document)
    Physical/Mechanical Performance
    CleanlinessISO 7864:2016 Clause 4.3; ISO 9626:2016 Clause 5.3Meets requirements (Implied by "complies with")
    Acidity/AlkalinityISO 7864:2016 Clause 4.4; ISO 9626:2016 Clause 5.4Meets requirements
    Extractable MetalsISO 7864:2016 Clause 4.5Meets requirements
    Size DesignationISO 7864:2016 Clause 4.6; ISO 9626:2016 Clause 5.5Meets requirements
    Color CodingISO 7864:2016 Clause 4.7; ISO 6009:2016Meets requirements
    Needle HubISO 7864:2016 Clause 4.8Meets requirements
    SheathISO 7864:2016 Clause 4.9Meets requirements
    Needle TubeISO 7864:2016 Clause 4.10Meets requirements
    Needle PointISO 7864:2016 Clause 4.11Meets requirements
    Bond (hub/tube)ISO 7864:2016 Clause 4.12Meets requirements
    Patency of LumenISO 7864:2016 Clause 4.13Meets requirements
    Surface FinishISO 9626:2016 Clause 5.1Meets requirements
    DimensionsISO 9626:2016 Clause 5.6Meets requirements
    StiffnessISO 9626:2016 Clause 5.7Meets requirements
    Resistance to BreakageISO 9626:2016 Clause 5.8Meets requirements
    Resistance to CorrosionISO 9626:2016 Clause 5.9Meets requirements
    Extraneous MatterISO 7886-1:2017 Clause 6Meets requirements
    LubricantISO 7886-1:2017 Clause 7Meets requirements
    Graduated Capacity ToleranceISO 7886-1:2017 Clause 8Meets requirements
    Graduated ScaleISO 7886-1:2017 Clause 9Meets requirements
    BarrelISO 7886-1:2017 Clause 10Meets requirements
    Piston/Plunger AssemblyISO 7886-1:2017 Clause 11Meets requirements
    NozzleISO 7886-1:2017 Clause 12Meets requirements
    General PerformanceISO 7886-1:2017 Clause 13Meets requirements
    Biocompatibility
    CytotoxicityISO 10993-5:2009No cytotoxicity / No negative impacts
    IrritationISO 10993-10:2010No intracutaneous reactivity / No negative impacts
    SensitizationISO 10993-10:2010No skin sensitization / No negative impacts
    Systemic ToxicityISO 10993-11:2017No systemic toxicity / No negative impacts
    HemolysisISO 10993-4:2017No Hemolysis / No negative impacts
    PyrogenPerformed (Result is "No Pyrogen" listed in Table 2)No Pyrogen / No negative impacts
    Sterilization & Packaging
    EO residueISO 11737-2:2019Did not exceed the limit
    Endotoxin limitNot specified standard, but a limit of 20EU/deviceDid not exceed 20EU/device
    Visual InspectionASTM F1886/F1886M-16Package can maintain its integrity
    Seal StrengthASTM F88/F88M-15Package can maintain its integrity
    Dye Penetration TestASTM F1929-15Package can maintain its integrity
    Shelf-LifePhysical, Mechanical, Chemical, Package TestsDevice can maintain its performance during claimed shelf life

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

    • Sample Size: The document does not specify exact sample sizes for each test. For medical device testing, samples are typically chosen according to relevant standard methods (e.g., lot-based sampling conforming to AQL – Acceptable Quality Level).
    • Data Provenance: Not explicitly stated regarding country of origin for the non-clinical test data. The tests were performed by "Weihai Shengjie Medical Technology Co., Ltd." in China, where the manufacturing entity is located. The tests are "nonclinical" (laboratory-based) and are implicitly prospective for the purpose of demonstrating compliance.

    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)

    • Not Applicable. This is a physical device, not an AI algorithm requiring expert ground truth for image interpretation or diagnosis. The "ground truth" is provided by the universally recognized and standardized test methods and their defined acceptance limits (e.g., ISO, ASTM standards).

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

    • Not Applicable. No human interpretation or adjudication of case data is involved for this type of device submission. Compliance is determined by objective physical, chemical, and biological test results against predefined standard thresholds.

    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 is not an AI-assisted device.

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

    • Not Applicable. This is not an AI algorithm.

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

    • The "ground truth" for this medical device's performance is compliance with established international and national standards (ISO, ASTM). These standards define the acceptable physical, mechanical, chemical, and biological properties for the device. For example, for biocompatibility, the ground truth is "no cytotoxicity" as per ISO 10993-5, determined by validated laboratory methods.

    8. The sample size for the training set

    • Not Applicable. This device uses traditional manufacturing and testing, not machine learning, so there is no "training set."

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

    • Not Applicable. As there is no training set for an AI/ML model, this question is irrelevant.
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