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510(k) Data Aggregation

    K Number
    K232330
    Device Name
    Lancing System
    Date Cleared
    2024-01-04

    (154 days)

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

    Lancet is intended to be used to obtain capillary blood sample for self-monitoring of blood glucose.

    Lancing Device is used with lancets to draw a capillary blood sample for testing, utilizing small amounts of blood. The Lancing Device is intended for use by a single patient and should not be shared.

    Device Description

    Lance Device have two parts, lancet and lancing device. Lancet is composed of a lancet body, a needle and a protective cap. Lancing device is mainly composed of depth adjustment tip, cap, release button, shield, rear sliding barrel and an ejector. The cover consists of inner cover, cap inner core, rear sliding barrel, inner core, buckle ring and two springs, with 12 depth adjustment gears.

    The lancet is provided as sterile state and have four model: Model BYY3, Model BYY4, Model BYB and Model BYC. The lancet body of Model BYY3 and Model BYY4 is circular, and the lancet body of Model BYB and Model BYC is flat. The lancing device is provided as non-sterile state and a reusable medical device for use only on a single patient and have four model: Model CX11B1, Model CX11B2, Model CX11C1 and Model CX11C2. Model CX11 Lancing device is divided into CX11B (threaded connection) and CX11C (buckle connection) according to the different connection structures of the cap and body of the lancing device. Model CX11B is divided into CX11B1 (suitable for round lancet) and CX11B2 (suitable for flat lancet) according to the different structure of the lancet. Model CX11C is divided into CX11C1(suitable for round lancet) and CX11C2(suitable for flat lancet) according to the different structures of the lancet.

    The lancet is sterilized by Gamma ray and for single use,the shelf life is 5 years. The lancing device is provided as non-sterile state,for use only on a single patient. The useful life is 5 years or 6000 times.

    AI/ML Overview

    This document primarily outlines the premarket notification (510(k)) for a Lancing System, focusing on demonstrating its substantial equivalence to a predicate device based on bench testing and biocompatibility assessments. It does not present a study with specific acceptance criteria and reported performance data for a standalone or human-in-the-loop AI/ML device.

    The document describes a medical device (Lancing System) used for obtaining capillary blood samples, not an AI/ML-driven diagnostic or assistive system. Therefore, the questions related to AI/ML specific performance, such as MRMC studies, standalone algorithm performance, expert ground truth establishment for test sets, and training set details, are not applicable to the information provided in this 510(k) summary.

    The "Performance testing summary" section (8.0 onwards) details bench testing and biocompatibility testing conducted to demonstrate the safety and effectiveness of the physical Lancing System, but these are not related to AI/ML performance.

    To address the prompt as much as possible given the provided text, I will describe the performance testing as presented for this physical medical device, acknowledging that it does not fit the AI/ML framework implied by many of the prompt's questions.


    Acceptance Criteria and Study for the Lancing System (Physical Device)

    This 510(k) submission for the Lancing System primarily focuses on demonstrating substantial equivalence to a predicate device through non-clinical bench testing and biocompatibility assessments, rather than evaluating an AI/ML-driven system. Therefore, the concepts of "acceptance criteria" and "reported device performance" are discussed in the context of the physical device's mechanical and biological properties, not AI/ML precision, recall, or reader improvement.

    1. Table of Acceptance Criteria and Reported Device Performance

    As this is a 510(k) submission for a physical medical device, specific numerical acceptance criteria and precise reported performance values are typically detailed in the full test reports, which are summarized here. The summary provides a list of tests conducted and a general statement that the device meets requirements or the tests show "well" performance.

    Test Item (Bench Testing)Acceptance Criteria (Implicit from industry standards/predicate)Reported Performance (Qualitative/Summary)
    Lancet Testing
    AppearanceConformance to specifications, freedom from defects"Tested" (Implies successful conformance)
    DimensionConformance to specified dimensions (e.g., needle length)"Tested" (Implies successful conformance), needle length 3.3 ± 0.5mm
    Needle-tipConformance to specifications for sharpness and integrity"Tested" (Implies successful conformance)
    Puncture forceWithin acceptable range for patient comfort and effectiveness"Tested" (Implies successful conformance)
    Connecting fastnessSecure connection with lancing device"Tested" (Implies successful conformance)
    Corrosion resistance featureResistance to corrosion for material longevity"Tested" (Implies successful conformance)
    Limits for acidity and alkalinityWithin biocompatible limits"Tested" (Implies successful conformance)
    Total heavy metal content and Cd contentBelow hazardous levels"Tested" (Implies successful conformance)
    Sealing strengthMaintenance of sterility barrier"Tested" (Implies successful conformance)
    Sterile barrier integrityMaintenance of sterility barrier"Tested" (Implies successful conformance)
    SterilitySterile when presented"Tested" (Implies successful conformance)
    Lancing Device Testing
    AppearanceConformance to specifications, freedom from defects"Tested" (Implies successful conformance)
    DimensionConformance to specified dimensions"Tested" (Implies successful conformance)
    CompatibilityProper function with specified lancets"Well compatibility"
    CoaxialityProper alignment of lancet for accurate puncture"Tested" (Implies successful conformance)
    Depth adjustmentAbility to adjust puncture depth as intended"Tested" (Implies successful conformance), max range 1.8mm ± 0.5mm with 12 gears
    Packages and LabelsConformance to regulatory and labeling requirements"Tested" (Implies successful conformance)
    Drop testStructural integrity after drops"Tested" (Implies successful conformance)
    Needle unloading thrustProper ejection of used lancet"Tested" (Implies successful conformance)
    Torque test (for CX11B1/B2)Mechanical robustness of threaded connection"Tested" (Implies successful conformance)
    Buckle force (for CX11C1/C2)Mechanical robustness of buckle connection"Tested" (Implies successful conformance)
    Separating force (for CX11C1/C2)Mechanical robustness of buckle connection"Tested" (Implies successful conformance)
    Biocompatibility Testing
    In vitro cytotoxicityNon-toxic to cellsCompleted, conformed to ISO 10993 series standards
    Skin sensitizationNon-sensitizing effectsCompleted, conformed to ISO 10993 series standards
    Intracutaneous reactivity (Lancet)Non-irritating when implanted/contacting tissueCompleted, conformed to ISO 10993 series standards
    Acute systemic toxicity (Lancet)Non-toxic acutely systemicallyCompleted, conformed to ISO 10993 series standards
    Pyrogen (Lancet)Non-pyrogenicCompleted, conformed to ISO 10993 series standards
    Skin Irritation (Lancing Device)Non-irritating to skinCompleted, conformed to ISO 10993 series standards
    Clinical Simulated Use Testing
    Sharps injury prevention featuresPrevention of sharps injuries during use and disposal"Well sharps injury prevention feature"

    2. Sample Size for the Test Set and Data Provenance

    • Sample Size: The document does not specify exact sample sizes for each bench test. For physical device testing, sample sizes are typically determined by relevant ISO standards (e.g., for sterility, dimensions, mechanical function) and internal quality control procedures.
    • Data Provenance: The document does not explicitly state the country of origin for the data collection, but the manufacturing company is "Ningbo Medsun Medical Co., Ltd." in "Ningbo, P.R.China," implying that the testing was likely conducted in China or by labs contracted within the region. The tests are presented as being conducted in support of the 510(k) submission, implying a prospective testing approach designed for regulatory clearance.

    3. Number of Experts and Qualifications for Ground Truth

    • Not Applicable: This pertains to AI/ML ground truth establishment. For a physical medical device, "ground truth" refers to the objective measurement against established standards (e.g., dimension measurements, force measurements, sterility cultures) rather than subjective expert consensus on image interpretation. Expert involvement would be in defining the standards, designing the tests, and interpreting the raw data, but not in establishing a "ground truth" derived from human interpretation.

    4. Adjudication Method for the Test Set

    • Not Applicable: This pertains to AI/ML test set ground truth. For physical device performance, adjudication is typically through statistical analysis of quantitative measurements against pre-defined acceptance limits, or pass/fail criteria for qualitative tests, not through expert consensus adjudication.

    5. Multi Reader Multi Case (MRMC) Comparative Effectiveness Study

    • Not Applicable: This concept is relevant for AI/ML systems that directly assist human readers (e.g., radiologists interpreting images). This submission is for a physical medical device (lancing system) and does not involve AI assistance for human tasks that would necessitate an MRMC study.

    6. Standalone (Algorithm Only) Performance

    • Not Applicable: This applies to AI/ML algorithms. The Lancing System is a physical device, and there is no standalone algorithm performance to evaluate.

    7. Type of Ground Truth Used

    • Objective Measurements/Standards: For this physical device, the "ground truth" is established by:
      • Referenced ISO Standards: The document repeatedly mentions adherence to ISO standards (e.g., ISO 10993 series for biocompatibility, ISO 23908:2011 for sharps injury protection, ISO 9626:2016 for needle gauges). These standards define the acceptable performance characteristics and test methods.
      • Engineering Specifications: Device dimensions, puncture force, and mechanical functions are measured against design specifications.
      • Laboratory Assay Results: Biocompatibility tests yield objective results (e.g., cell viability, presence of pyrogens) against established acceptable ranges.
      • Qualitative Assessments: Appearance and functional tests are performed against defined visual and operational criteria.

    8. Sample Size for the Training Set

    • Not Applicable: There is no "training set" as this is not an AI/ML device.

    9. How the Ground Truth for the Training Set was Established

    • Not Applicable: As there is no AI/ML training set, this question is not relevant.
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