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510(k) Data Aggregation
(245 days)
Hematology (HO)
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(77 days)
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The Administration Sets are intravenous administration sets intended for delivery of medications and fluids from a container into a patient's vascular system.
The EZ™ IV Administration Set is a gravity, single use, disposable, intravenous administration set designed to deliver fluids from a container into a patient's vascular system. The device includes a vented bag spike (air vent 0.1µm) integrated to a drip chamber (not made with DEHP*) featuring a 5-μm particulate filter, a roller clamp, flexible IV tubing (not made with DEHP*), and one (1), two (2) or three (3) needle-free valve (NFV) Y-site connectors. It also features a Luer connector and a priming cap with a 3-μm filter.
The EZ™ IV Administration Set may be used in combination with standard IV therapy devices commonly used throughout the healthcare settings, such as bag spike, Luer lock adaptor, syringe (MLL) (without needle), and IV extension sets. It is configured to achieve the intended use when used with these standard complementary products.
*DEHP – Di (2-ethylhexyl) phthalate (DEHP), a plasticizer to make PVC soft and flexible. It is a substance known to cause cancer or reproductive toxicity.
The provided FDA 510(k) clearance letter and summary for the EZ™ IV Administration Set (K251814) describe the device's acceptance criteria and the studies conducted to demonstrate substantial equivalence to a predicate device. However, this document primarily focuses on demonstrating substantial equivalence rather than proving the device meets specific acceptance criteria for a novel device. It also describes a medical device rather than a software or AI-driven device, so several of the requested categories (e.g., sample size for test set, number of experts, adjudication method, MRMC study, training set details) are not applicable.
Here's an analysis based on the provided text, focusing on the available information:
Acceptance Criteria and Device Performance for EZ™ IV Administration Set (K251814)
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria for the EZ™ IV Administration Set are primarily defined by adherence to recognized international and national standards for intravascular administration sets and specific functional performance metrics derived from these standards. The reported device performance indicates compliance with these standards.
Characteristic Compared | Acceptance Criteria (Standard Reference) | Reported Device Performance (Subject Device) |
---|---|---|
Performance Testing | Conformance with: |
- ISO 8536-4:2019
- ISO 22413:2021
- ISO 10993-1:2018
- ANSI/AAMI CN27:2021
- ISO 80369-7:2021
- ISO 80369-20:2015
- FDA Guidance for Intravascular Administration Sets | Comprehensive performance verification & validation testing performed; met the intended use. |
| Air-inlet device tests | ISO 8536-4:2019 | Conformed to standard. |
| Flow rate test | ISO 8536-4:2019 | Conformed to standard. |
| Piercing device penetration force test | ISO 22413:2021 | Conformed to standard. |
| Protective cap removal test | ISO 8536-4:2019 | Conformed to standard. |
| Drip chamber and drip tube tests | ISO 8536-4:2019 | Conformed to standard. |
| Leak integrity tests | ISO 8536-4:2019 (air leakage under positive pressure, air leakage under negative pressure and fluid leakage) | Conformed to standard. |
| Tensile strength test | ISO 8536-4:2019 | Conformed to standard. |
| Particulate contamination level | ISO 8536-4:2019, Annex A, A.2
USP Particulate Matter in Injections | Met contamination index, N≤90. Conformed to standard. |
| Drops/mL | 20 gtt/mL (as per Predicate) | 20 gtt/mL |
| Tubing transparency | Sufficiently clear to observe air/water interface (normal/corrected vision) | Conformed to standard. |
| Connector type | External Fitting Male Luer Lock (ISO 80369-7:2021) | Conformed to standard. |
| Sterile barrier packaging | Medical grade paper and plastic film, heat sealed | Conformed to standard. |
| Sterilization process | Ethylene Oxide (EO), SAL 10⁻⁶ | Ethylene Oxide (EO), SAL 10⁻⁶. Complies with ISO 11135:2014. |
| Shelf-life validation | 3 years (36 months) via ASTM 1980-21 | 3 years (36 months) validated. |
| Biocompatibility | ISO 10993-1:2018 (Externally Communicating Device, Blood Path Indirect, Prolonged Contact)
(Specific ISO 10993 parts for various tests) | Met biological safety specifications. |
| EO residues limits | ISO 10993-7:2008 & amendments | Conformed to standard. |
| Shipping | ASTM D 4169-16 | Simulated shipping testing performed on K151650/S004. |
| Package integrity | ASTM F1980-21, ASTM F88/F88M-21, ASTM F1929-23, EN 868-5:2009 | Testing performed on K151650. |
| Pyrogen tests | ANSI/AAMI ST72/2019, USP , USP , USP | Testing performed on K151650 and "will be conducted on every lot." |
2. Sample size 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 the exact sample sizes (number of devices/batches) used for each specific performance test mentioned (e.g., flow rate, leak integrity, tensile strength). The studies are focused on product characteristics and compliance with engineering standards, not clinical patient data.
- Data Provenance: Not explicitly stated for each test. The submitter is "Epic Medical Pte. Ltd." based in Singapore, suggesting the testing data likely originated from or was managed by facilities associated with this company. The testing is for a medical device component, not a diagnostic algorithm, so there is no patient data involved in these performance tests.
- Retrospective or Prospective: Not applicable, as these are engineering and materials performance tests conducted on the physical device itself.
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)
This information is not applicable to this type of device submission. The "ground truth" here is defined by objective engineering specifications and international standards, rather than expert consensus on medical images or diagnoses. Qualification involves expertise in medical device testing, engineering, and regulatory compliance.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. Adjudication methods are relevant for subjective assessments, typically in clinical readings or evaluations where human interpretation introduces variability. These are objective physical and chemical tests on a medical device.
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 a physical medical device (IV administration set), not an AI-powered diagnostic tool, and therefore no MRMC studies were conducted or are relevant.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This is a physical medical device, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
The "ground truth" for the performance tests conducted on the EZ™ IV Administration Set is based on established international and national standards and their specific test methods and acceptance criteria. This includes standards like ISO 8536-4 for infusion sets, ISO 10993 for biocompatibility, and USP for particulate matter. These standards provide objective, measurable criteria for device performance and safety.
8. The sample size for the training set
Not applicable. This pertains to the training of an algorithm or AI model. This submission is for a physical medical device.
9. How the ground truth for the training set was established
Not applicable. As above, this is for a physical medical device and does not involve a training set for an algorithm.
Summary of Study that Proves Device Meets Acceptance Criteria:
The study that proves the EZ™ IV Administration Set meets its acceptance criteria is a comprehensive set of performance verification and validation tests conducted on the subject device and, in some cases, leveraging data from the predicate device (K230343/S001) or an existing device (K151650 and K151650/S004).
These tests address:
- Functional Performance: Evaluated against ISO 8536-4:2019, ISO 22413:2021, and FDA guidance documents, covering aspects like flow rate, leak integrity, piercing device penetration force, protective cap removal, drip chamber performance, and tensile strength.
- Connection Integrity: Evaluated against ANSI/AAMI CN27:2021 (for luer-activated valves) and ISO 80369 series (for small-bore connectors like Luer lock).
- Biocompatibility: Evaluated against ISO 10993 series (e.g., -5, -10, -11, -17, -18, -23) to assess cytotoxicity, sensitization, systemic toxicity, hemolysis, pyrogenicity, and chemical characterization. This classification was for "Externally Communicating Device, Blood Path Indirect, Prolonged Contact (>24 hr to 30 d)."
- Sterility and Shelf-Life: Compliance with ISO 11135:2014 for Ethylene Oxide sterilization, ASTM D 4169-16 for shipping, and ASTM F1980-21 for accelerated aging (shelf-life validation of 3 years). Package integrity, pyrogen, and EO residue tests were also part of this.
- Material Composition: Analysis and risk assessment were conducted given differences in materials between the subject and predicate devices, leveraging biocompatibility and chemical characterization data.
The submitter states that "All performance testing demonstrated and confirmed the safety and effectiveness of the Subject device" and that the results "met the intended use." They explicitly noted for material and dimension differences that "analytical and functional testing were conducted" and "the results...demonstrated that the performance of the Subject devices met the intended use. Therefore, the differences were considered not significant." This body of evidence constitutes the study proving the device meets its acceptance criteria, which are primarily compliance with the listed international and national standards.
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(252 days)
Hematology (HO)
The SmartPilot YpsoMate NS-A2.25 is indicated for use with the compatible disposable autoinjector to capture and record injection information that provides feedback to the user.
The SmartPilot YpsoMate NS-A2.25 is an optional, battery operated, reusable device designed to be used together with a compatible autoinjector (a single use, needle based, pre-filled injection device for delivery of a drug or biologic into subcutaneous tissue). Figure 1 shows the SmartPilot YpsoMate NS-A2.25 with the paired autoinjector. The SmartPilot YpsoMate NS-A2.25 records device data, injection data and injection process status. The SmartPilot YpsoMate NS-A2.25 also provides guidance feedback to the user during the injection.
Note that the SmartPilot YpsoMate NS-A2.25 does not interfere with autoinjector function.
The provided 510(k) clearance letter details the substantial equivalence of the SmartPilot YpsoMate NS-A2.25 device to its predicate. While it lists various performance tests and standards met, it does not contain specific acceptance criteria values or detailed study results for metrics like sensitivity, specificity, or improvement in human reader performance. This document primarily focuses on demonstrating that the new device does not raise new questions of safety and effectiveness compared to the predicate, due to similar technological characteristics and adherence to relevant safety standards.
Therefore, many of the requested details about acceptance criteria, study design (sample size, data provenance, expert adjudication, MRMC studies), and ground truth establishment (especially for AI-driven performance) cannot be extracted directly from this regulatory document. The information primarily pertains to hardware, software, and usability testing.
However, based on the provided text, here's what can be inferred or stated about the device's acceptance criteria and proven performance:
Device: SmartPilot YpsoMate NS-A2.25
Indication for Use: The SmartPilot YpsoMate NS-A2.25 is indicated for use with the compatible disposable autoinjector to capture and record injection information that provides feedback to the user. Specifically compatible with Novartis/Sandoz Secukinumab (Cosentyx).
1. Table of Acceptance Criteria and Reported Device Performance
The document does not provide a table with quantitative acceptance criteria and reported performance values for metrics typically associated with AI/software performance (e.g., sensitivity, specificity, accuracy of data capture in a clinical context). Instead, it focuses on meeting established engineering, safety, and quality standards.
Here's a summary of the types of performance criteria implied by the successful completion of the listed tests:
Acceptance Criterion (Implied) | Reported Device Performance (Achieved) | Supporting Test / Standard |
---|---|---|
Biocompatibility | Meets requirements for intact skin contact. | ISO 10993-1, -5, -10, -23 |
Compatibility with Autoinjector | No negative impact on Essential Performance Requirements (EPRs) of compatible YpsoMate 2.25ml autoinjector. | ISO 11608-1:2022, ISO 11608-5:2022 (Influence Testing) |
Basic Safety | Complies with general safety standards. | IEC 60601-1, Ed.3.2 2020-08 |
Electromagnetic Compatibility (EMC) | Complies with EMC standards. | IEC 60601-1-2:2014 incl. AMD 1:2021 |
Battery Safety | Complies with battery safety standards. | IEC 62133-2:2017 + A1:2021 |
Wireless Communication (FCC) | Complies with FCC regulations for wireless devices. | FCC 47 CFR Part 15B, Part 15.225, Part 15.247 |
Wireless Coexistence | Complies with standards for wireless coexistence. | IEEE ANSI USEMCSC C63.27-2021; AIM 7351731:2021 |
Software Verification & Validation | Documentation level "enhanced," meets requirements for safety, cybersecurity, and interoperability. Software classified as B per ANSI AAMI ISO 62304:2006/A1:2016. | FDA Guidance on Software Functions, ANSI AAMI ISO 62304, Cybersecurity Testing, Interoperability testing |
Electrical Hardware Functionality | BLE, NFC, inductance measurement, electromechanical switches, motion detection, temperature measurement all functional. | Electrical Hardware Requirements Testing |
Indicator & Feedback Systems | Visual (LEDs with specified wavelength/intensity) and acoustic (adjustable sound volume) feedback systems are functional. | Electrical Hardware Requirements Testing |
Durability & Lifetime | Meets specifications for switching cycles, 3-year storage, 2-year or 120-use operational lifespan, and operational tolerances. | Electrical Hardware Requirements Testing, Lifetime and Shelf Life Testing |
Mechanical Integrity | Withstands use force, axial/twisting loads on inserted autoinjector, and maintains locking flag visibility. | Mechanical Testing |
Shelf Life | Achieves a 3-year shelf life. | Shelf Life Testing |
Human Factors/Usability | Complies with human factors engineering standards; formative and summative usability evaluations completed. | IEC 60601-1-6:2010/AMD2:2020, ANSI AAMI IEC 62366-1:2015 + AMD1 2020 |
Transportation Safety | Maintains integrity after transportation simulation. | ASTM D4169-22 |
Dose Accuracy (Influence) | Meets ISO 11608-1 requirements when evaluated with compatible YpsoMate AutoInjectors. This is related to the autoinjector's performance when used with the SmartPilot, not the SmartPilot's accuracy in measuring dose itself, as it states the SmartPilot "does not capture dosing information." | Influence Testing based on ISO 11608-1:2022 |
Note: The device's primary function is to "capture and record injection information that provides feedback to the user," and it "does not capture dosing information" or "electronically controlled dosing." Therefore, criteria related to dosing volume accuracy or AI interpretation of medical images/signals for diagnosis are not applicable to this device. The focus is on the accurate capture of event data (injection start/end, result) and providing timely feedback, as well as general device safety and functionality.
2. Sample Size Used for the Test Set and Data Provenance
The document describes various types of tests (e.g., Biocompatibility, EMC, Software V&V, Mechanical, Lifetime, Human Factors), but does not specify the sample sizes used for each test dataset.
Data Provenance: The document does not explicitly state the country of origin for the data or whether the studies were retrospective or prospective. Given that Ypsomed AG is based in Switzerland and the testing references international and US standards, the testing likely involved a mix of internal validation, third-party lab testing, and possibly user studies in relevant regions. All tests described are part of preclinical (non-clinical) performance validation, making them inherently prospective for the purpose of demonstrating device function and safety prior to marketing.
3. Number of Experts and Qualifications for Ground Truth
The document does not mention the use of experts in the context of establishing ground truth for the device's functional performance, as it is not an AI-driven diagnostic or interpretative device that relies on human expert consensus for its output. Its performance is evaluated against engineering specifications and physical/software functional requirements. The "Human Factors" testing would involve users, but not necessarily "experts" adjudicating correctness in the sense of accuracy for a diagnostic task.
4. Adjudication Method for the Test Set
Not applicable. The device's performance is determined by meeting pre-defined engineering and regulatory standards and testing protocols, not by expert adjudication of its output, as it does not produce subjective or interpretative results like an AI diagnostic algorithm.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
Not performed/applicable. An MRMC study is relevant for AI systems that assist human readers in tasks like image interpretation to demonstrate improved diagnostic accuracy. This device is an "Injection Data Capture Device" providing feedback and recording information; it does not involve human readers interpreting data that the device enhances.
6. Standalone (Algorithm Only) Performance
While the device has software and algorithms to detect injection events and provide feedback, the document does not report "standalone" performance metrics in the way an AI diagnostic algorithm would (e.g., sensitivity, specificity). Its performance is demonstrated through the verification and validation of its hardware and software components (e.g., ability to detect spring position, successful data transfer, correct LED/audible feedback). The "Influence Testing" evaluates its performance in conjunction with the autoinjector, proving it does not negatively interfere.
7. Type of Ground Truth Used
The ground truth for the verification and validation of this device is engineering specifications, physical measurements, and adherence to established regulatory and industry standards. For example:
- Biocompatibility: Measured against established thresholds for cytotoxicity, sensitization, and irritation.
- EMC/Safety: Compliance with current versions of IEC standards.
- Software V&V: Compliance with software lifecycle processes and cybersecurity standards, and correct execution of defined functions (e.g., data recording, feedback activation).
- Mechanical/Lifetime: Physical measurements (e.g., activation force, dimension checks), cycle counts, and functional checks after simulated use/aging.
- Human Factors: User performance and subjective feedback against usability goals.
There is no "expert consensus," "pathology," or "outcomes data" ground truth in the context of its direct function (data capture and feedback).
8. Sample Size for the Training Set
Not applicable. This device is not an AI/machine learning system that requires a "training set" in the conventional sense (i.e., for learning to perform a complex, data-driven task like image recognition or diagnosis). Its functionality is based on programmed logic and sensor readings, not statistical learning from a large dataset.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there is no "training set" for the type of device described. Input signals (e.g., from the inductive sensor about spring position) are processed based on predefined engineering parameters and logical rules to determine injection status, not learned from a dataset.
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(20 days)
Hematology (HO)
Powder-Free Vinyl Exam Gloves, clear is a disposable device intended for medical purposes that is worn on the examiner's hand to prevent contamination between patient and examiner.
The subject device is a powder free vinyl patient examination glove, provided as non-sterile and disposable device. It is provided with clear color. Available in four sizes small, medium, large, and extra - large users can choose the most suitable option.
The provided FDA 510(k) clearance letter and summary describe the regulatory approval process for "Powder-Free Vinyl Exam Gloves, clear." This is a Class I medical device, and the clearance is based on demonstrating substantial equivalence to a predicate device, K220469, "Disposable Vinyl Examination Glove."
The study described is not a clinical study involving human patients or complex AI algorithms necessitating multi-reader, multi-case (MRMC) studies or expert adjudication of medical images. Instead, it's a non-clinical performance study focused on the physical, chemical, and biological properties of the gloves.
Therefore, many of the requested points related to AI performance, human reader improvement, and complex ground truth establishment for medical diagnosis are not applicable to this type of device and study.
Here's the breakdown of the information that is applicable:
Acceptance Criteria and Device Performance for Powder-Free Vinyl Exam Gloves, Clear
The acceptance criteria and device performance are primarily based on non-clinical testing according to recognized industry standards (ASTM and ISO). The goal is to demonstrate that the subject device meets the same performance specifications as the predicate device.
1. Table of Acceptance Criteria and Reported Device Performance
Methodology (Standard) | Test Performed | Acceptance Criteria | Reported Device Performance | Outcome |
---|---|---|---|---|
ASTM D5250-19, ASTM D3767-03 | Physical Dimensions: Length | S/M/L/XL: 230 mm | 230 mm | Pass |
Physical Dimensions: Width | S: 85±5 mm; M: 95±5 mm; L: 105±5 mm; XL: 115±5 mm | S: 85-86 mm; M: 95-96 mm; L: 104-106 mm; XL: 115-116 mm | Pass | |
Physical Dimensions: Thickness | Finger: 0.08 mm; Palm: 0.08 mm | Finger: 0.09-0.12 mm; Palm: 0.08-0.10 mm | Pass | |
ASTM D5250-19, ASTM D412-16 | Physical Properties: Before aging (Tensile strength) | 11 MPa, min | 14 - 22 MPa | Pass |
Physical Properties: Before aging (Ultimate elongation) | 300%, min | 302 - 419 % | Pass | |
Physical Properties: After aging (Tensile strength) | 11 MPa, min | 14 - 21 MPa | Pass | |
Physical Properties: After aging (Ultimate elongation) | 300%, min | 303 - 433 % | Pass | |
ASTM D5250-19, ASTM D5151-19 | Water leak test (Freedom from holes) | G-I, AQL 2.5 (ISO 2859-1) | Pass | Pass |
ASTM D5250-19, ASTM D6124-06 | Powder Residue | Max 2 mg/glove | 0.37-0.53 mg | Pass |
ISO 10993-10:2021 | Sensitization | Non-sensitizing | Under conditions of the study, not a sensitizer. | Pass |
ISO 10993-23:2021 | Irritation | Non-irritating | Under the conditions of the study, not an irritant. | Pass |
ISO 10993-5:2009 | Cytotoxicity | Non-Cytotoxicity | Under conditions of the study, device is not cytotoxic. | Pass |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: The document does not specify a precise numerical sample size (e.g., number of gloves) for each non-clinical test. However, it indicates that testing was performed according to the specified ASTM and ISO standards, which inherently define the necessary sample sizes and methodologies for ensuring statistical validity within their respective contexts (e.g., AQL for the water leak test).
- Data Provenance: The document does not explicitly state the country of origin for the data. Given the "Basic Medical Technology Inc." is located in Ontario, CA (presumably California, USA) and the predicate device manufacturer is a Chinese company (CHIFENG HUAWEI MEDICAL SCIENCE TECHNOLOGY CO., LTD.), the testing could have been performed either in the US, China, or accredited labs elsewhere.
- Retrospective or Prospective: This testing is inherently prospective as it involves the manufacturing and testing of new device samples to demonstrate compliance with standards.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
- Not Applicable: For this type of non-clinical device (medical gloves), "ground truth" is not established by medical experts interpreting images or clinical data. Instead, it's established by the physical and chemical properties of the material as measured by standardized laboratory methods. The "experts" would be the accredited laboratory personnel performing the tests according to the ASTM and ISO standards, not medical professionals like radiologists.
4. Adjudication Method for the Test Set
- Not Applicable: Adjudication methods (e.g., 2+1, 3+1) are used for resolving discrepancies in expert interpretations of complex data (like medical images). This is a physical product testing scenario where results are quantitative measurements against objective criteria, so no adjudication by multiple human observers is required.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- Not Applicable: An MRMC study is relevant for evaluating the impact of AI algorithms on human reader performance in tasks like diagnostic imaging. This device is a pair of medical gloves; there is no AI component or human reader interpretation task involved.
6. Standalone (i.e., algorithm only without human-in-the-loop performance) Study
- Not Applicable: This pertains to AI algorithm performance evaluation. There is no AI algorithm in "Powder-Free Vinyl Exam Gloves, clear." The "standalone" performance here refers to the device's physical and biological properties.
7. Type of Ground Truth Used
- The "ground truth" for this device is based on objective, standardized measurements of its physical properties (e.g., dimensions, tensile strength, elongation, hole detection) and biological compatibility (e.g., cytotoxicity, irritation, sensitization), as defined by internationally recognized ASTM and ISO standards. It is not based on expert consensus, pathology, or outcomes data in the clinical sense.
8. Sample Size for the Training Set
- Not Applicable: This is not an AI/machine learning device. Therefore, there is no "training set" in the context of an algorithm. The manufacturing process of the gloves would have its own quality control and process validation, which might involve data collection analogous to a training set for process refinement, but this is distinct from AI model training.
9. How the Ground Truth for the Training Set Was Established
- Not Applicable: As there is no AI training set, this question is irrelevant.
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(84 days)
Hematology (HO)
The glove is a disposable device intended for medical purposes that is worn on the examiner's hand to prevent contamination between patient and examiner.
Gloves were tested for use with Chemotherapy drugs, Fentanyl Citrate, Simulated Gastric acid and Xylazine in Fentanyl Citrate in accordance with ASTM D6978-05 Standards Practice for assessment of Medical Glove to Permeation by chemotherapy drugs.
Nitrile Powder-Free Exam Gloves Tested for Use with Chemotherapy Drugs, Opioid Fentanyl Citrate, Simulated Gastric Acid and Xylazine in Fentanyl Citrate is a Class I patient examination glove and specialty chemotherapy gloves, that made from synthetic nitrile latex. They are pink color, non-sterile, powder-free, fingertip textured, ambidextrous with beaded cuff, and single use only, and come in different sizes- XS, S, M, L, XL and XXL.
The device meets all the specifications in ASTM D6319-19, Standard specification for Nitrile Examination Gloves. Additionally, the gloves have been been tested for biocompatibility and permeability to chemotherapy drugs, Fentanyl Citrate, Gastric Acid and Xylazine in Fentanyl Citrate.
This document describes the acceptance criteria and the study that proves the device meets the acceptance criteria for a medical device submitted for FDA 510(k) clearance.
The device in question is Nitrile Powder-Free Exam Gloves Tested for Use with Chemotherapy Drugs, Opioid Fentanyl Citrate, Simulated Gastric Acid and Xylazine in Fentanyl Citrate.
Acceptance Criteria and Device Performance Study
The acceptance criteria for this device are primarily based on established industry standards for medical examination gloves and specific permeation resistance tests for various chemical substances. The study conducted to prove the device meets these criteria is a series of non-clinical performance tests.
1. Table of Acceptance Criteria and Reported Device Performance
Test Performed | Methodology | Acceptance Criteria | Reported Device Performance |
---|---|---|---|
Freedom From Holes | ASTM D6319-19, ASTM D5151-19 | Meet requirement inspection level G-1, AQL 2.5 (ISO2859-1) | Pass |
Dimension - Length | ASTM D6319-19 | Minimum 220mm for size XS-S | |
Minimum 230mm for size M-XXL | Pass | ||
Dimension - Width | ASTM D6319-19 | XS: 70±10mm | |
S: 80±10mm | |||
M: 95±10mm | |||
L: 110±10mm | |||
XL: 120±10mm | |||
XXL: 130±10mm | Pass | ||
Dimension - Thickness | ASTM D6319-19 | Finger: 0.05mm (min) | |
Palm: 0.05mm (min) | Pass | ||
Physical Properties | ASTM D6319-19, ASTM D412-16 | Before aging: | |
Tensile Strength (Min 14 Mpa) | |||
Elongation (Min 500%) | |||
After aging: | |||
Tensile Strength (Min 14 Mpa) | |||
Elongation (Min 400%) | Pass (All criteria met) | ||
Powder Residue | ASTM D6319-19, ASTM D6124-06 | Not more than 2 mg per glove | Pass |
Skin Irritation (Biocompatibility) | ISO10993-23:2021 | Under the conditions of the study, not a primary skin irritant | Pass (Not a primary skin irritant) |
Skin Sensitization (Biocompatibility) | ISO10993-10:2021 | Under the conditions of the study, not a contact sensitizer | Pass (Not a contact sensitizer) |
Acute Systemic Toxicity (Biocompatibility) | ISO 10993-11:2017 | Under the conditions of the study, no signs of acute systemic toxicity were observed | Pass (No signs of acute systemic toxicity were observed) |
Chemotherapy Drugs Permeation | ASTM D6978-05 (2023) | Minimum Breakthrough Detection Time (minutes) | |
Carboplatin: >240 | |||
Carmustine: Varies (15.3 min reported) | |||
Cisplatin: >240 | |||
Cyclophosphamide: >240 | |||
Cytarabine HCl: >240 | |||
Dacarbazine: >240 | |||
Daunorubicin HCl: >240 | |||
Doxorubicin HCl: >240 | |||
Etoposide: >240 | |||
5-Fluorouracil: >240 | |||
Gemcitabine HCl: >240 | |||
Ifosfamide: >240 | |||
Irinotecan HCl: >240 | |||
Mechlorethamine HCl: >240 | |||
Melphalan HCl: >240 | |||
Methotrexate: >240 | |||
Mitomycin-C: >240 | |||
Mitoxantrone HCl: >240 | |||
Pacilitaxel: >240 | |||
Thiotepa: Varies (28.2 min reported) | Carboplatin: >240 min. | ||
Carmustine: 15.3 min. | |||
Cisplatin: >240 min. | |||
Cyclophosphamide: >240 min. | |||
Cytarabine HCl: >240 min. | |||
Dacarbazine: >240 min. | |||
Daunorubicin HCl: >240 min. | |||
Doxorubicin HCl: >240 min. | |||
Etoposide: >240 min. | |||
5-Fluorouracil: >240 min. | |||
Gemcitabine HCl: >240 min. | |||
Ifosfamide: >240 min. | |||
Irinotecan HCl: >240 min. | |||
Mechlorethamine HCl: >240 min. | |||
Melphalan HCl: >240 min. | |||
Methotrexate: >240 min. | |||
Mitomycin-C: >240 min. | |||
Mitoxantrone HCl: >240 min. | |||
Pacilitaxel: >240 min. | |||
Thiotepa: 28.2 min. | |||
Note: The document explicitly states that Carmustine and Thiotepa have "extremely low permeation times" and are accompanied by a "Warning: Do not use with Carmustine and Thiotepa," indicating that the stated permeation times for these two drugs are not >240 minutes and are accepted for the specified usage. | |||
Fentanyl, Gastric Acid, Xylazine Permeation | ASTM D6978-05 (2023) | Minimum Breakthrough Detection Time (minutes) | |
Fentanyl Citrate Injection: >240 | |||
Simulated Gastric Acid: >240 | |||
Fentanyl Citrate:Xylazine HCl (50:50): >240 | Fentanyl Citrate Injection: >240 min. | ||
Simulated Gastric Acid: >240 min. | |||
Fentanyl Citrate (50mcg/ml): Xylazine HCl (100mg/ml), 50:50: >240 min. |
2. Sample Size Used for the Test Set and Data Provenance
The document does not explicitly state the specific sample sizes (number of gloves) used for each individual test. However, it indicates that the tests were conducted according to established ASTM and ISO standards, which typically specify appropriate sample sizes for such tests to ensure statistical validity.
The data provenance is through non-clinical testing performed in accordance with recognized international and national standards (ASTM, ISO). This implies the data were prospectively generated for the purpose of this submission. The country of origin of the data is not specified, but the use of international standards suggests a globally accepted testing methodology.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This information is not applicable (N/A) as the device is a physical product (medical glove) and the performance is evaluated through objective, standardized laboratory tests (e.g., measuring permeation time, tensile strength, dimensions) rather than expert interpretation of images or clinical data. There is no "ground truth" established by human experts in the context of diagnostic accuracy for this type of device.
4. Adjudication Method for the Test Set
This information is not applicable (N/A) for the same reason as above. Adjudication methods like 2+1 or 3+1 are relevant for studies involving human interpretation (e.g., radiology reads) where discrepancies need to be resolved. The tests performed for this device are objective measurements.
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 information is not applicable (N/A). This document pertains to the clearance of a physical medical device (gloves), not an AI algorithm or a diagnostic imaging device that would involve human readers.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was Done
This information is not applicable (N/A). As mentioned, this is a physical medical device, not a software algorithm.
7. The Type of Ground Truth Used
The "ground truth" for this device's performance is established by objective, quantitative measurements obtained through standardized laboratory testing methodologies (ASTM and ISO standards). For example:
- Permeation: Measured breakthrough time of specific chemicals through the glove material.
- Physical Properties: Measured tensile strength, elongation, length, width, and thickness.
- Biocompatibility: Observed biological responses (e.g., irritation, sensitization, systemic toxicity) in controlled in-vitro or in-vivo (animal) tests as per ISO standards.
This is not based on expert consensus, pathology, or outcomes data in the clinical sense, but rather on direct physical and chemical testing.
8. The Sample Size for the Training Set
This information is not applicable (N/A). This device is a manufactured product that undergoes performance and biocompatibility testing. There is no "training set" in the context of machine learning. The manufacturing process is designed and validated to consistently produce gloves meeting the specified criteria.
9. How the Ground Truth for the Training Set was Established
This information is not applicable (N/A) as there is no training set for this device. The "ground truth" for the device's design and manufacturing is derived from the established standards (ASTM, ISO) that define the performance characteristics expected of such gloves. Quality control during manufacturing ensures conformity to these standards.
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(268 days)
Hematology (HO)
Monoject Syringes with Luer tip are intended for single use by health care professionals for general purpose fluid aspiration and and/or injection.
Not Found
The provided FDA 510(k) clearance letter pertains to Monoject™ Syringes, which are physical medical devices (piston syringes) and not an AI/ML software device. Therefore, the concepts of acceptance criteria for algorithm performance, study methodology for AI models, sample sizes for training/test sets, ground truth establishment, expert adjudication, or MRMC studies are not applicable to this document.
The letter indicates that the device has received substantial equivalence to legally marketed predicate devices, meaning it meets the safety and effectiveness requirements for its intended use, which is general purpose fluid aspiration and/or injection by healthcare professionals.
To answer your request, if this were an AI/ML device, the information would typically be found in the 510(k) submission summary or a separate clinical study report, neither of which is present in the provided FDA clearance letter. The letter itself is a notice of clearance, not a detailed technical report of the studies performed.
Therefore, I cannot extract the requested information from the provided document as it does not contain details about an AI/ML study or its performance criteria.
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(34 days)
Hematology (HO)
A patient examination gloves is a disposable device intended for medical purpose that is worn on the examiner's hand or fingers to prevent contamination between patient and examiner. In addition, these gloves were tested for use with chemotherapy drugs, fentanyl citrate, xylazine, gastric acid, fentanyl in gastric acid and xylazine in gastric acid in accordance with ASTM D6978-05 Standard Practice for Assessment of Resistance of Medical gloves to Permeation by Chemotherapy Drugs.
Warning: do not use with Carmustine and Thiotepa.
The maximum testing time is 240 minutes. Please note that the following drug has an extremely low permeation time:
- Carmustine (BCNU) 3.3 mg/ml 21.5 minutes
- Thiotepa 10.0 mg/ml 13.6 minutes
"Disposable Powder Free Nitrile Examination Glove, Blue Color, Tested For Use With Chemotherapy Drugs, Fentanyl Citrate, Xylazine, Gastric acid, Fentanyl in Gastric acid and Xylazine in Gastric acid" is a patient examination glove made from nitrile compound, non-sterile (as per 21 CFR 880.6250, Class I). The principle operation of this medical device is to provide single use barrier protection for the wearer and the device meets the specifications for Barrier Protection and tensile properties as defined in ASTM D6319-19, Standard specification for Nitrile Examination Gloves.
The provided document is an FDA 510(k) clearance letter for a medical device: "Disposable Powder Free Nitrile Examination Glove, Blue Color, Tested For Use With Chemotherapy Drugs, Fentanyl Citrate, Xylazine, Gastric acid, Fentanyl in Gastric acid and Xylazine in Gastric acid."
This is a physical medical device (a glove), not a software device or an AI/ML algorithm. Therefore, many of the requested categories related to AI/ML model validation (e.g., sample size for test set, data provenance, number of experts for ground truth, adjudication methods, MRMC studies, standalone performance, training set details) are not applicable to this type of FDA submission.
The document assesses the device's physical properties and its resistance to permeation by various hazardous substances. The "acceptance criteria" and "study that proves the device meets the acceptance criteria" refer to bench testing against established ASTM and CFR standards for medical gloves.
Here's the breakdown of the relevant information from the document, tailored to the nature of this device:
Acceptance Criteria and Device Performance for Disposable Nitrile Examination Gloves
1. Table of Acceptance Criteria and Reported Device Performance
The device (Disposable Powder Free Nitrile Examination Glove, Blue Color) was tested against several physical and chemical permeation standards. The acceptance criteria and results are outlined in the "Assessment of Non-Clinical Performance Data" section (Page 17-19) and the "Indications for Use" section (Page 4-5) and summarized within the "510(k) Summary" (Page 7-11).
Test | Test Method | Purpose | Acceptance Criteria | Results |
---|---|---|---|---|
Dimension | ASTM D6319-19 | Determine the geometrical dimension of gloves | Length: Short cuff: ≥230mm; Long cuff: ≥300mm | |
Thickness: Palm: ≥ 0.05 mm; Finger: ≥ 0.05 mm; Cuff: ≥ 0.05 mm | ||||
Palm Width: XS: 70 ± 10 mm; S: 80 ± 10 mm; M: 95 ± 10 mm; L: 110 ± 10 mm; XL: 120 ± 10 mm | Pass | |||
Freedom from holes (Water leak) | 21 CFR 800.20. & ASTM D5151-19 | Detect the holes on the gloves. | G-I/ AQL 2.5 | Pass |
Tensile strength (Before aging/ After aging) | ASTM D6319-19 | Evaluate the tensile (tension) properties of the gloves. In addition, it also determines the influence of elevated temperature on the physical properties of gloves. | Before Aging: ≥14MPa | |
After Aging: ≥14MPa | Pass | |||
Elongation (Before aging/ After aging) | ASTM D6319-19 | Related to tensile properties, measures stretchiness. | Before Aging: ≥500% | |
After Aging: ≥400% | Pass | |||
Powder Residual | ASTM D6319-19 | Determine the average powder mass found on the gloves | < 2mg per glove | Pass |
Biocompatibility - Cytotoxicity | AAMI/ANSI/ISO 10993-5 | Determine the cytotoxicity potential of glove | No in vitro cytotoxic as described in ISO 10993-5 | Pass |
Biocompatibility - Skin Sensitization and Irritation | AAMI/ANSI/ISO 10993-10 | Determine the potential of glove to promote skin sensitization after repeated applications. | ||
Determine the potential of gloves to promote skin irritation after repeated applications. | No dermal reactions indicative of delayed contact hypersensitivity | |||
No skin irritation, cumulative irritation index to be 0. | Pass | |||
Resistance of Gloves to Permeation by Chemotherapy and Other Liquid Hazardous Drugs, and Non-drugs Solution | ASTM D6978-05 | Assessment of medical gloves to permeation by chemotherapy and other liquid hazardous drugs, and non-drugs solution. | The resistance of the device to permeation were challenged against 59 hazardous drugs and 1 non-drugs simulated solution. | |
General Acceptance Standard (Implicit): Maintain barrier protection for a minimum period. The tables on pages 4-5 and 7-11 list Minimum Breakthrough Detection Time (Min.) for each substance. For most substances, the acceptance criterion was ">240 minutes", meaning no breakthrough occurred within the 240-minute test period. For Carmustine and Thiotepa, specific breakthrough times (21.5 and 13.6 minutes, respectively) were observed and noted as limitations/warnings. | Pass |
2. Sample size used for the test set and the data provenance:
- Sample Size: The document does not explicitly state numerical sample sizes for each specific test (e.g., how many gloves were tested for a burst, tensile, or permeation). However, it implies that testing was conducted according to the specified ASTM and FDA methodologies, which inherently define minimum sample sizes for material testing (e.g., AQL levels for freedom from holes).
- Data Provenance: The tests are "bench testing" conducted on physical glove samples. The manufacturer is "Ever Global (Vietnam) Enterprise Corporation" from Vietnam, so the testing was likely conducted in accordance with international standards at a facility associated with the manufacturer or a certified testing lab. The data is non-clinical performance data from laboratory experiments, not patient data.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not Applicable. As this is a physical device subject to material property and permeation testing, "ground truth" is established by adherence to physical measurement standards and chemical analysis protocols (e.g., ASTM D6319-19 for physical properties, ASTM D6978-05 for permeation). No human expert interpretation or consensus is required to establish the "truth" of a chemical breakthrough time or tensile strength value.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- Not Applicable. Adjudication methods are relevant in subjective human interpretation tasks (e.g., radiology image reading). For objective bench testing of physical properties, results are determined by instrumentation and adherence to standardized protocols, not human adjudication.
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. MRMC studies are used for evaluating the impact of AI on human reader performance, typically in medical imaging. This is a physical glove, not an AI-assisted diagnostic tool.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not Applicable. This is a physical device, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):
- The "ground truth" is established through objective, standardized laboratory measurement methods as defined by the referenced ASTM (American Society for Testing and Materials) and CFR (Code of Federal Regulations) standards.
- For physical properties (Dimensions, Tensile Strength, Elongation, Powder Residual, Freedom from Holes), the ground truth is the measured physical values against the defined thresholds in ASTM D6319-19 and 21 CFR 800.20 & ASTM D5151-19.
- For chemical permeation (Resistance to Hazardous Drugs), the ground truth is the measured breakthrough time determined by chemical analysis according to ASTM D6978-05.
- For Biocompatibility, the ground truth is the biological response (cytotoxicity, dermal reactions) as measured per AAMI/ANSI/ISO 10993-5 and 10993-10 standards.
8. The sample size for the training set:
- Not Applicable. This is a physical product, not a machine learning model; therefore, there is no "training set." The product's design and manufacturing process are developed through engineering and material science, not data training.
9. How the ground truth for the training set was established:
- Not Applicable. As there is no training set for this physical device.
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