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510(k) Data Aggregation

    K Number
    K240774
    Device Name
    Pen Injector
    Date Cleared
    2024-06-18

    (89 days)

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

    The Pen Injector is a re-usable pen injector designed for single patient use by diabetics for the self-injection of a desired dose of insulin. The Pen Injector uses HUMALOG (insulin lispro) injection (U-100) available in 3 mL cartridges, and a single use detachable and disposable insulin pen needle (supplied separately, needle sizes including: 32G4mm, 31G4mm, 31G5mm, and 31G6mm).

    Device Description

    The Pen Injector is a reusable mechanical pen-injector capable of injecting a dose of up to 80 units of insulin, in 1 unit increments. The Pen Injector consists of a pen injector body, a push block, a injection button, a dose display window, a dose adjustment knob, a reservoir and a pen injector cap. The intended dose is mechanically set by rotating a dose adjustment knob. The insulin is injected by depressing the knob which mechanical coupling causes the piston in the insulin cartridge to move forward thereby expelling the intended dose. The Pen Injector is intended for single user and provided for non-sterile.

    AI/ML Overview

    The provided document describes the FDA 510(k) clearance for the Wuxi NEST Biotechnology Co., Ltd. Pen Injector (K240774). The acceptance criteria and supporting studies are primarily focused on performance testing to demonstrate substantial equivalence to the predicate device, NovoPen Echo® (K182387).

    Here's a breakdown of the requested information:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria / Performance MetricRequirement/StandardReported Device Performance (Pen Injector K240774)
    Dose AccuracyISO 11608-1:2022Meets ISO 11608-1:2022 requirements
    Injection ForceISO 11608-1:2022Meets ISO 11608-1:2022 requirements
    Injection TimeISO 11608-1:2022Meets ISO 11608-1:2022 requirements
    Biocompatibility - CytotoxicityISO 10993-5:2009Meets requirements
    Biocompatibility - Skin SensitizationISO 10993-10:2021Meets requirements
    Biocompatibility - IrritationISO 10993-23:2021Meets requirements
    Compatible with 3mL HUMALOG (insulin lispro) U-100 cartridgesDemonstrated compatibilityCompatible
    Compatible with specified pen needlesDemonstrated compatibilityCompatible (listed sizes: 32G4mm, 31G4mm, 31G5mm, 31G6mm)
    Shelf Life5 years (verified by accelerated aging)5 years
    Service Life (reuse cycles)3,000 times3,000 times
    Transportation ResistanceASTM D4169:2022Functions as intended after transportation

    2. Sample Size Used for the Test Set and Data Provenance

    The document does not specify the exact sample sizes (e.g., number of devices, cartridges, or test repetitions) used for each individual performance test (dose accuracy, injection force, injection time, biocompatibility, shelf life, service life, transportation). It generally states that "corresponding performance tests were conducted" or "aging studies have been conducted."

    The provenance of the data is from Wuxi NEST Biotechnology Co., Ltd. in China, and the studies are prospective in nature, conducted specifically to demonstrate the performance of the Pen Injector for this submission.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts

    This information is not applicable to the reported studies. The performance tests rely on objective measurements against established international standards (ISO, ASTM) and not on human expert interpretation or ground truth establishment in a medical context.

    4. Adjudication Method for the Test Set

    Not applicable. The tests are based on direct physical and chemical measurements against pre-defined thresholds from international 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 device is a mechanical pen injector, not an AI-powered diagnostic or imaging device, so MRMC studies or human reader performance with AI assistance are not relevant.

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

    This refers to the core performance testing of the device (dose accuracy, injection force, etc.) which demonstrates the standalone capabilities of the Pen Injector mechanism without human-in-the-loop performance evaluation in a clinical setting. The tests confirm the device's inherent mechanical functionalities meet the specified standards.

    7. The Type of Ground Truth Used

    The "ground truth" for the performance tests outlined is defined by:

    • International Standards: ISO 11608-1:2022 (for injection system performance), ISO 10993 series (for biocompatibility), ASTM F1980-16 (for accelerated aging/shelf life), and ASTM D4169:2022 (for transportation).
    • Device Specifications: The inherent design parameters and intended performance of the Pen Injector (e.g., maximum dose, dial increments, service life).

    8. The Sample Size for the Training Set

    Not applicable. This device is a mechanical medical device, not an AI/machine learning model, so there is no concept of a "training set."

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

    Not applicable, as no training set is involved for this type of device.

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