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510(k) Data Aggregation

    K Number
    K221778
    Date Cleared
    2022-10-03

    (104 days)

    Product Code
    Regulation Number
    878.4850
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Disposable Safety Lancets is intended to be used in a hospital or at home to obtain capillary blood samples from the fingertip for tests using small amounts of blood. The device contains a sharp injury protection feature.

    Device Description

    The Disposable Safety Lancets consists 7 parts, include a lancet cap, body, slide, lancet, tip cover, spring and bottom. The models of the Disposable Safety Lancets are 18G; 21G; 23G; 26G; 28G; 30G; 32G; 33G. The Disposable Safety Lancets is intended to be used in a hospital or at home to obtain capillary blood samples from the fingertip for tests using small amounts of blood. The device contains a sharp injury protection feature. The lancet is hit by pressure, and once the device strikes, the lancet needle can puncture the skin. Used Gamma sterilization, and are products for single use.

    AI/ML Overview

    The provided document describes a 510(k) premarket notification for "Disposable Safety Lancets" by Suzhou Kyuan Medical Apparatus Co., Ltd. This document primarily focuses on demonstrating substantial equivalence to a predicate device rather than presenting a clinical study of AI performance. Therefore, many of the requested details related to an AI-driven device's acceptance criteria and study proving its performance (e.g., MRMC studies, training set details, expert ground truth) are not applicable to this submission.

    However, the document does contain information about performance testing for the mechanical and biological aspects of the lancet. I will extract the relevant information for the acceptance criteria and performance of the device itself (the lancet), not a hypothetical AI component, as well as indicating where information is not present or not applicable based on the nature of the submission.


    Acceptance Criteria and Device Performance (Non-AI Device)

    1. Table of Acceptance Criteria and Reported Device Performance

    No.Testing ItemAcceptance Criteria (Specification)Reported Device Performance (Result)
    01AppearanceDisposable Safety Lancets the surface should be smooth without edge, no dirt and damage, deformation and other poor appearance.Pass
    02Launch LengthThe length of the needles in the Disposable Safety Lancet is different in different genders and ages. The launch length of the needle is determined according to the length of the purchase, and the general emission length is 1.2mm-2.8mm.Pass
    03SharpnessPenetration force ≤1.00N.Pass
    04Feature (Safety)The tip of the needle can shrink quickly after firing, and the tip of the needle is not exposed.Pass
    05Feature (Single Use)Disposable Safety Lancets Only one launch, not another.Pass
    06Initial BioburdenInitial bioburden of the device shall be less than 100CFU/gPass
    07SterileThe sterile blood lancet shall be sterilePass

    Biocompatibility Testing:

    ItemTest MethodAcceptance Criteria (Implicit: No adverse reaction)Reported Device Performance (Result)
    Cytotoxic testISO 10993-5:2009No CytotoxicityNo Cytotoxicity
    Skin sensitization testISO 10993-10:2010No Skin sensitizationNo Skin sensitization
    Intracutaneous testISO 10993-10:2010No irritationNo irritation
    Acute systemic toxicity testISO 10993-11:2017No Acute Systemic ToxicityNo Acute Systemic Toxicity
    Hemolysis testISO 10993-4:2017No HemolysisNo Hemolysis
    Pyrogen TestUSP <151>Non-pyrogenicNon-pyrogen

    Sterilization and Shelf Life Testing:

    • Irradiation sterilization validation: Per ISO 11173-1 and ISO 11173-3 (Pass, implied by conclusion of substantial equivalence).
    • Pyrogen testing: Per USP <151> (Pass, as listed in biocompatibility).
    • Simulated shipping: Per ASTM D4169 (Pass, implied by conclusion of substantial equivalence).
    • Shelf life: 5 years determined based on stability study which includes ageing test (Pass, implied by conclusion of substantial equivalence).

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

    The document does not specify the exact sample sizes (number of units tested) for each of the performance or biocompatibility tests. It broadly states "The following performance data were provided in support of the substantial equivalence determination." This is common for 510(k) summaries where detailed protocols and raw data are part of the full submission but not typically presented in this summary format.

    Data Provenance: Not explicitly stated beyond "non-clinical testing." It's generally assumed these tests were conducted at the manufacturer's or contracted labs (often in China, given the manufacturer's location in Suzhou, P.R.China) as part of their quality system requirements. These are laboratory tests of device properties, not clinical data from patients.

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

    This is not applicable as this is a submission for a physical medical device (lancet), not an AI device that requires expert-established ground truth for image or data interpretation. The "ground truth" for the lancet specifications is based on physical measurements, mechanical properties testing, and standardized biological/chemical tests performed in a lab setting, not human expert consensus.

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

    This is not applicable as there is no human interpretation or subjective assessment that would require an adjudication method for this type of device testing.

    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. This is not an AI-assisted device.

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

    This is not applicable. This is not an AI device.

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

    The "ground truth" for this device's performance is based on pre-defined engineering specifications, material properties, and standardized biological safety endpoints (e.g., a penetration force <= 1.00N, sterility, no cytotoxicity). These are objective measurements and test results, not subjective expert consensus or clinical outcomes data in a broad sense.

    8. The sample size for the training set

    This is not applicable. This is not an AI device and does not involve a training set.

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

    This is not applicable. This is not an AI device and does not involve a training set.

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